Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
Respondent determined by notices of deficiency dated April 6, 1982 and June 10, 1982 for the taxable years ended December 31, 1978 and December 31, 1979, respectively, deficiencies in petitioners' Federal income taxes as follows:
Taxable Year1 Deficiency 1978 ............ $3,539.24 1979 ............ 3,038.00...
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