Memorandum Opinion
GALLOWAY, Special Trial Judge.
These consolidated cases were heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1954 and Rules 180, 181, and 182.
By notices of deficiency dated July 11, 1988 (for the year 1984) and March 24, 1989 (for the years 1985-1987), respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
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