Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income taxes as follows:
Docket Taxable No. Petitioner Year Deficiency 28410-81 Michael Cronin 1977 $21,852.00 and Sharon Cronin 1978 7,969.00 358-82 Seymour Koehl and 1977 21,821.00 Ruth J. Koehl ...
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