Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined deficiencies of $19,637.06 and $2,553.00 in petitioners' Federal income taxes for the taxable years 1977 and 1978, respectively. The sole issue for decision is the validity of Forms 872-A, Special Consents to Extend the Time to Assess Tax, at the time of their execution and their continued effect at the time the deficiency notice herein was issued.
Findings of Fact
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