MEMORANDUM OPINION
NIMS, Judge:
In these consolidated cases, respondent determined the following deficiencies with respect to the Federal income taxes of petitioners Ivor F. and Debra A. Benci-Woodward (the Benci-Woodwards), Laurentz J. and Barbara Mangum (the Mangums), and Jose and Dianne M. Ragatz (the Ragatzes):
(the... Docket No. 3769-96
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