MEMORANDUM OPINION
CARLUZZO, Special Trial Judge:
Respondent determined deficiencies of $6,621, $9,500, and $9,012 in petitioners' Federal income taxes for years 1994, 1995, and 1996, respectively. For each year in issue, the issue for decision is whether deductions for losing wagers and related expenses attributable to gambling transactions are limited by the gains from such transactions.
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