Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By two notices of deficiency dated November 27, 1984, respondent determined the following deficiencies in petitioners' Federal income tax:
Year Deficiency Jonas R. Bryant ...... 1979 $203,492.52 Jonas R. and Carmen L. Bryant .............. 1982 9,088.00
The issues for decision are: (1) whether petitioner...
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