Memorandum Opinion
HAMBLEN, Chief Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1980, 1981, and 1982 in the amounts of $22,743, $25,568, and $38,443, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the sole issue for...
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