Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Taxable Year Ended Deficiency 12/31/77 ................................ $ 2,861.24 12/31/80 ................................ 11,306.48 12/31/81 ................................ 7,213.00
After concessions,
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