Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a timely statutory notice of deficiency dated June 28, 1983, respondent determined deficiencies in petitioners' joint Federal income tax for 1976, 1977, 1978, and 1979 as follows:
Year Deficiency 1976 ........................ $ 39,350.40 1977 ........................ 65,905.87 1978...
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