Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Petitioners Stephen W. Baumgart and Margaret G. Baumgart are husband and wife and resided in Reston, Virginia, when the petition in this case was filed. Petitioner Stephen W. Baumgart is hereafter referred to as "petitioner."
Respondent determined deficiencies in petitioners' Federal income tax of $114,712 and $18,380 for the years 1975 and 1976, respectively. After concessions by both parties...
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