Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in the Federal income tax of petitioners for the taxable year 1972 in these amounts:
Docket No. Petitioner Deficiency 8719-77 Frank Spenger Co. ....... $61,754 8720-77 Estate of Frank Spenger, Sr., Deceased, Frank Spenger, Jr., Executor, and Marcella Spenger, ...
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