NIMS, Judge:
Respondent determined the following income tax deficiencies in these consolidated cases:
Docket No. Petitioners Taxable years Deficiency 16346-82 Weldon T. Peters 1978 $8,270,85 40418-85 and Linda C. Peters 1979 6,568.00 43688-85 Donal B. Hepworth 1978 6,402.00 and Verna J. Hepworth 1979 8,873.00 ...
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