Memorandum Findings of Fact and Opinion
COHEN, Judge:
In a notice of deficiency dated July 7, 1981, respondent determined a deficiency of $779 in petitioners' Federal income taxes for the calendar year 1978. In a notice of deficiency dated March 23, 1982, respondent determined deficiencies of $917 and $892 in petitioners' Federal income taxes for the years 1979 and 1980, respectively. Petitioners dispute respondent's disallowance of petitioners' deduction...
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