Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined an $11,980.17 deficiency in petitioners' 1974 income tax. The issues for decision are: (1) whether petitioners are entitled to business, rental and itemized expenses in excess of the amounts allowed by respondent; (2) whether petitioners established their basis in a capital asset sold in 1974; and (3) whether petitioners are liable for damages under section 6673
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