Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1978 through 1983 as follows:
Year Deficiency 1978 .......................... $ 166,764 1979 .......................... 82,086 1980 .......................... 104,054 1981 .......................... 181,446 1982 ...................
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