Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable year 1974 as follows:
Docket No. Petitioner Deficiency 13813-78 Michael J. Sackett and Catherine S. Sackett....... $23,303.78 13814-78 Walter J. Sackett, Jr., and Joyce V. Sackett .......... 27,630.30
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