Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in Ronald H. Doneff's (hereinafter petitioner) and Isabelle Doneff's (together hereinafter referred to as petitioners) Federal income tax for the taxable years 1981 and 1984 in the amounts of $22,714.39 and $10,745.11, respectively.
The issues presented are: (1) Whether petitioners' consent to extend the statute of limitations, executed by their agent, was...
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