Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Docket No. 12491-89 Year Deficiency 1982 .......................... $16,277.50 1983 .......................... 13,761.50 Docket No. 12492-89 1984 .......................... $12,104.00
After concessions, the...
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