Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In these consolidated cases respondent on April 11, 1985, mailed a notice of deficiency to Marilyn G. Dooley in which respondent determined deficiencies in her income taxes as follows:
Year Deficiency 1979 ...................... $ 8,769.68 1980 ...................... 24,347.63 1981 .........
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