Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1976 of $37,560.17. The issues for decision are (1) whether this case should be dismissed with prejudice against respondent because of his alleged concession of no deficiency and his issuance of an allegedly arbitrary and erroneous deficiency notice, (2) whether petitioners or the "Lelah M. Truxal Equity Trust" earned...
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