Memorandum Opinion
GERBER, Judge:
Respondent determined income tax deficiencies for petitioners' 1979, 1980, 1981, and 1982 taxable years. Separate notices were issued for 1979 and 1980 and another for 1981 and 1982. Separate notices were apparently required because petitioners filed jointly for 1981 and 1982 and separately for 1979 and 1980. The only substantive adjustments were made to the 1982 taxable year. The 1979, 1980, and 1981 tax years are involved...
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