Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Separate notices of deficiencies were issued by the respondent to the petitioners in which respondent determined that there were deficiencies in the income taxes due from the petitioners for 1978 and 1979 in the amounts of $1,564.00 and $2,681.08, respectively. A separate petition was filed by the petitioners for each year but the cases were consolidated for trial, briefing and opinion. Therefore by...
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