MEMORANDUM OPINION
FOLEY, Judge:
By notice dated June 24, 1998, respondent determined deficiencies in, and penalties relating to, Stephen and Doralynn Goodman's 1994 and 1995 Federal income taxes. By notice dated July 16, 1998, respondent determined deficiencies in, and penalties relating to, John and Phyllis Ray's 1993 and 1995 Federal income taxes. After concessions, the sole issue for decision is whether...
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