HALL, Judge:
Respondent determined deficiencies in petitioners' income taxes as follows:
Petitioners Year Deficiency Silvano and Carol Achiro Docket No. 467-79 ---------- 1975 $13,414 1976 19,979 Peter and Gemma Rossi Docket No. 468-79 ---------- 1975 13,417 1976 20,061 ...
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