MEMORANDUM FINDINGS OF FACT AND OPINION
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners Michael and Madeline Friedman's 1989 and 1990 Federal income tax in the amounts of $686,400 and $793,860, respectively. Respondent also determined deficiencies in petitioners Edward and Deborah Rosenthal's 1989 and 1990 Federal income tax in the amounts of $617,446, and $811,723, respectively.
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