MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Charles L. Fields and Barbara S. Fields petitioned the Court to redetermine respondent's determinations with respect to their 1980 through 1982 taxable years. Respondent determined deficiencies of $525,389, $243,493, and $1,365 in their 1980, 1981, and 1982 Federal income taxes, respectively. Respondent
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