Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Petitioner Year Deficiency John M. Egan1 .... 1977 $1,205 1978 1,235 John M. Egan, M.D., P.C. .......... FYE 9/30/772 539 ...
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