Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
For the calendar years 1979 and 1980, respondent determined deficiencies in income tax against petitioners in the respective amounts of $6,245 and $6,523. All such amounts were placed in issue by the petition herein.
Although some eleven issues were raised by the pleadings, as the result of negotiations and concessions by the parties prior to and at trial, the issues remaining for determination...
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