Memorandum Findings of Fact and Opinion
LARO, Judge:
This case is before the Court pursuant to a petition filed by Elbert Budin and Shirley Budin (petitioners) for redetermination of respondent's determinations reflected in two notices of deficiency issued to them on June 18, 1992. Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
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