MEMORANDUM OPINION
KORNER, Judge:
By timely notice of deficiency, respondent determined deficiencies in petitioners' Federal income tax in the amounts of $220,039 for 1988 and $240 for 1989. The case was submitted to the Court on a set of fully stipulated facts and exhibits under Rule 122. Except as hereinafter noted, all statutory references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules...
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