Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice dated June 10, 1992, respondent determined deficiencies in Federal income tax of petitioners Maurice A. and Jacqueline Mosley, docket No. 20269-92 as follows:
Year Deficiency 1987 ............................... $2,981 1988 ............................... 3,064 1989 ............................... 4,709 1990 .......
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