Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in the petitioners' Federal income taxes:
Taxable year Deficiency 1979 ........ $4,042.83 1980 ........ 9,762.58
In addition, respondent amended his answer with respect to taxable year 1979 to claim an increased deficiency in the amount of $1,680 based on disallowance of petitioners' claimed partnership losses...
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