Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated August 12, 1991, respondent determined deficiencies against petitioners as follows:
Year Deficiency 1972 ........................ $24,426 1973 ........................ 3,477 1974 ........................ 3,898
Unless otherwise noted, all section references are to the Internal Revenue Code...
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