Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
In these consolidated cases, respondent determined by separate notices of deficiency dated January 31, 1984 deficiencies in the Federal income taxes of petitioners for the taxable years ended December 31, 1981 and December 31, 1982 in the amounts of $662 and $1,226, respectively.
After concessions,
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