Memorandum Findings of Fact and Opinion
BEGHE, Judge:
By separate statutory notices of deficiency, respondent determined deficiencies in petitioners' Federal income tax and an addition to tax as follows:
Petitioner John M. Gaughan, Docket No. 150-91 Year Deficiency 1984 .................... $236,901Petitioner Gloria J. Gaughan, Docket No. 259-91 ...
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