MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1993, 1994, and 1995 as follows:
Year Deficiency 1993 .............................. $37,804 1994 .............................. 44,796 1995 .............................. 49,306
After settlement of some issues, the primary issue remaining...
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