MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
In these consolidated cases, the parties have stipulated deficiencies in petitioners' Federal income taxes for 1979, 1980, 1981, and 1982 as follows:
Year Deficiency 1979 $ 7,662 1980 13,123 1981 22,834 1982 16,069
The parties have also stipulated that these deficiency amounts constitute substantial underpayments...
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