Memorandum Opinion
GALLOWAY, Special Trial Judge.
These consolidated cases were heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined, in a notice of deficiency for the years 1980 and 1981 dated March 15, 1985, and in a notice of deficiency for the year 1982 dated February 10, 1989, deficiencies and additions to tax in petitioner's Federal income taxes as follows:
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