Memorandum Opinion
CLAPP, Judge:
This matter is before the Court on petitioners' Motion for Partial Summary Judgment and respondent's Cross-Motion for Partial Summary Judgment pursuant to Rule 121.
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1976 ................. $22,847.00 1977 ................. 18,747.00 ...
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