Memorandum Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Year Deficiency 1976 .......... $1,356 1977 .......... 8,303 1978 .......... 6,217
This case is presently before the Court on respondent's motion for summary judgment, and petitioners' cross-motion for partial summary judgment, under Rule 121.
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