MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency (the notice), respondent determined a deficiency of $259,874 in petitioners' 1997 Federal income tax. By the petition, petitioners assign error to respondent's determination. Petitioners also assign error to respondent's denial of their claims for refund for 1997. The allowance of one or more of those claims would result in a refund of $45,400, the amount of tax petitioners paid...
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