MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Taxable Year Deficiency 1982 ........................ $3,036 1985 ........................ 1,933 1986 ........................ 3,787 1987 ........................ 4,781
Unless otherwise indicated, all section references...
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