MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $18,905, $16,465, and $15,434 for taxable years 1990, 1991, and 1992, respectively. Petitioners Martin Abbene and Marion Abbene will individually be referred to as Mr. Abbene or Mrs. Abbene, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years...
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