Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Dkt. No. Petitioners Year Deficiency 2000-76 Vernon J. Cristina 1971 $10,201 and Antoinette Cristina 2001-76 Jess A. Rodrigues 1971 $21,830 and Jeralyn Rodrigues
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