Memorandum Findings of Fact and Opinion
LARO, Judge.
This case is before the Court pursuant to petitions for redetermination of Federal income tax liability filed on behalf of: (1) John H. and Janet M. Heger, (2) George E. and Gail Y. Heger, and (3) James C. and Molly A. Heger. Following a motion by respondent under Rule 141(a),
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