MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Year Taxpayer(s) Deficiency 1993 Michale H. Gulley $ 3,671 1993 Paula M. Gulley 7,986 1994 Michael H. and Paula M. Gulley 68,321
Petitioner Michael H. Gulley (petitioner) owned a 66.67-percent general...
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