Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioners' income tax as follows:
Petitioners Docket No. Year Amount Merle W. and Sarah Nicewander .......... 5634-72 1968 $ 76,256.64 1969 28,813.39 Florian V. and Kathryn O'Day ........... 5635-72 1968 104,405.27 ...
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