MEMORANDUM FINDINGS OF FACT AND OPINION
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Respondent determined deficiencies in petitioners' 1993, 1994, and 1995 Federal income taxes in the amounts of...
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