OPINION
Swift, Judge:
In timely statutory notices of deficiency, respondent determined deficiencies in petitioners' Federal income tax liabilities as follows:
Petitioners Year Deficiencies Robert J. Miller 19761 $5,805 and Susan F. Miller 1979 60,877 Samuel Edelman 1979 9,024 and Sylvia Edelman Phillip Paley 1979 5,496...
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