MEMORANDUM FINDINGS OF FACT AND OPINION
PAJAK, Special Trial Judge:
Respondent determined deficiencies in petitioners' 1994, 1995, and 1996 Federal income taxes in the amounts of $1,583, $1,562, and $1,551, respectively. 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.
The sole issue for decision is whether rental payments received by...
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