OPINION
SWIFT, Judge:
In timely statutory notices of deficiency, and in an amended answer in docket No. 9325-83, respondent determined deficiencies in petitioners' Federal income tax liabilities, as follows:
Taxable year Petitioners ending— Deficiency Marcus W. and Marilyn E. Melvin— Dec. 31, 1979 $21,340 docket No. 9325...
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