Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:
Taxable Year Deficiency Petitioners Ended Owensby & Kritikos, Inc. 9/30/79 $ 51,724 Petro-Marine Engineering, 10/31/78 208,544 Inc., and Subsidiaries 9/30/79 197,122 John W...
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