SWIFT, Judge:
In timely statutory notices of deficiency dated October 12, 1984, respondent determined the following deficiencies in petitioners' 1980 and 1981 Federal income taxes:
Petitioner Docket No. Year Deficiency Frank L. Levy 1132-85 1980 $31,682 1981 79,237 Lee & Leon Oil Co. 1133-85 1980 69,173 ...
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