HAMBLEN, Chief Judge:
Respondent determined deficiencies in the Federal income tax liability of George S. Nalle, III, and Carole Nalle (petitioners) as follows:
Year Deficiency 1980 .............................. $6,163.32 1983 .............................. 2,638.75 1984 .............................. 14,012.54 1985 .............................. 260,804.61 <...
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