SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income taxes for 1977 as follows:
Docket No. Petitioner Deficiency 22699-82 Heinz Molsen, Jr., $243,048 and Christina T. Molsen 22700-82 Frederick G. Molsen 243,048 and Jayne F. Molsen 22701-82 Peter F. Kandel ...
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