MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $2,799 and $2,991 for the taxable years 1995 and 1996. Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by the parties, this Court must decide...
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