MEMORANDUM OPINION
FAY, Judge:
Respondent determined deficiencies of $10,756 and $10,974 in petitioners' 1994 and 1995 Federal income taxes, respectively. After concessions, the issue for decision is whether section 469(c)(7)(D)(ii)
This is a fully stipulated case that was submitted without a trial under Rule 122. We incorporate in this opinion the parties' stipulation of facts and the exhibits....
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