MEMORANDUM OPINION
HAMBLEN, Chief Judge:
These consolidated cases are before the Court on respondent's motion for summary judgment under Rule 121. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
By notice of deficiency dated January 28, 1993, respondent determined the following deficiencies in, and additions...
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