Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioners' income taxes for the calendar years 1976 through 1980 in the following amounts:
Year Deficiency 1976 ......................... $21,295.00 1977 ......................... 37,631.00 1978 ......................... 198,945.00 1979 ......................... 4,070.00 1980 .............
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