Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:
Taxable Docket No. Year Ended Deficiency 11763-81 Sept. 30, 1975 $ 13,980.00 Sept. 30, 1976 591.00 11764-81 Dec. 31, 1974 115,317.00 Dec. 31, 1975 14,393.00 Dec. 31, 1976 3,119...
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