Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in income tax due from petitioners as follows:
Petitioners Docket No. Year Deficiency Estate of Samuel Rosenberg, Elliot Appel, Executor, and Beatrice Rosenberg ...................................... 9268-85 1979 $27,293 Beatrice Rosenberg ........
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