Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in the income tax due from petitioners as follows:
Taxable Year Deficiency 1976 $ 3,046.001 1977 85,501.00 1978 7,187.07
After concessions, the issues remaining for decision are: (1) whether the distribution by K & K Insurance Administrators...
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