Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in income tax for the years in issue as follows:
Year Ended Deficiency March 31, 1985 .................... $21,655.11 March 31, 1986 .................... 25,642.04 March 31, 1987 .................... 32,764.89
The issues presented for our decision are as follows: (1) Whether income derived by...
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