OPINION
EKMAN, Judge:
These cases are before the Court on petitioners Arnold and Mary J. Abramo's motion for summary judgment and petitioner Mary Louise Abramo's cross-motion for summary judgment, pursuant to Rule 121, Tax Court Rules of Practice and Procedure. Respondent determined deficiencies in petitioners' 1974, 1975, and 1976 Federal income taxes as follows:
Arnold and Mary J....
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