Memorandum Findings of Fact and Opinion
WELLS, Judge:
In Docket No. 28826-84 respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Against petitioner John P. Crowley:
Year Deficiency 1976 ................. $ 52,437 1977 ................. 11,913 1978 ................. 31,302
Against petitioners:
Year ...
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