Memorandum Opinion
KöRNER, Judge:
By notice of deficiency dated April 15, 1985, respondent determined the following deficiencies in petitioners' Federal income tax:
Tax Year Deficiency 1980 .................. $31,824.28 1981 .................. 73,200.83 1982 .................. 46,370.84
After concessions by respondent,
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