OPINION
NIMS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Docket No. Tax year ended— Deficiency 32041-84 Dec. 31, 1979 $4,767.77 Dec. 31, 1980 1,577.06 36453-84 Dec. 31, 1979 3,031.29 Dec. 31, 1980 16,472.46 Dec. 31, 1981 13,919.88 36454-84 June 30, 1980 901.00 ...
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