CHABOT, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioners for 1981 as follows:
Petitioners Deficiency H. Dale Gunther and Marie M. Gunther .............. $185,019 Gene W. Gunther and Lois H. Gunther ............... 185,353 James L. Bjorkman and Penelope A. Bjorkman...
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