MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge.
Respondent determined deficiencies of $1,570 and $570 in petitioners' 1992 and 1993 Federal income taxes, respectively.
The issues for decision are: (1) Whether petitioners are entitled to exclude all of their income from Federal income taxation, and (2) whether petitioners are entitled to deduct payments made into a reserve account.
FINDINGS OF FACT
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