Memorandum Findings of Fact and Opinion
WILES, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners' Federal income taxes:
Year Deficiency Uwe Schmidt and Helga I.M. Schmidt ... 1973 $ 2,369.09 1974 9,196.51 1975 2,128.00 1976 1,756.001
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