MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
These consolidated cases involve income tax deficiencies determined by respondent for petitioners' 1994 taxable year. Respondent determined a $14,672 deficiency for petitioners William A. and Ann M. Jacobs, Docket No. 626-98, and a $13,200 deficiency for petitioners John W. and Phyllis M. Connelly, Docket No. 627-98. These cases were consolidated for trial, briefing, and opinion pursuant to Rule 141...
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