MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
Respondent determined deficiencies of $3,759 and $4,187 in petitioner's 1995 and 1996 Federal income taxes, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.
The issues for decision for each year in issue are: (1) Whether petitioner...
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