MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years 1992 and 1993. Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners' 1992 and 1993 Federal income taxes in the...
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