MEMORANDUM OPINION
TANNENWALD, Judge:
Respondent determined the following deficiencies in the 1993 Federal income taxes of Leslie R. Foster (Leslie) and Mattie J. Foster (Mattie), Charles W. Payne (Charles) and Carole B. Payne (Carole), and Wayne G. Smith (Wayne) and Marie Smith (Marie):
Docket No. Deficiency Leslie and Mattie Foster ..... 19932-94 $16,303 Charles and Carole Payne ....
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