Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
In these consolidated cases the respondent determined the following deficiencies in the 1973 income tax of petitioners:
Docket No. Petitioner Deficiency 1529-77 Estate of Shirley Joy Thoda, Deceased, William H. Thoda, Executor ............. $1,153.75 4536-77 Connie Mack Gurley ........... 2,935.22
Petitioner estate was substituted...
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