Memorandum Findings of Fact and Opinion
LARO, Judge:
The case is before the Court pursuant to the filing of two petitions by James A. Kuhl (petitioner) for a redetermination of respondent's determinations set forth in her separate notices of deficiency issued to petitioner on April 5, 1991, and September 30, 1991. On May 3, 1993, we granted respondent's motion to consolidate petitioner's cases for trial, briefing, and opinion. Respondent determined deficiencies...
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