MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Liberty Vending, Inc., docket No. 23958-96 Year Deficiency 1991 .............................. $ 2,272 1993 .............................. 3,750 John Poulos, docket No. 23959-96 Year ...
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