MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
By notices dated February 9 and June 23, 2000, respondent determined deficiencies in petitioners' 1994, 1995, and 1996 Federal income taxes of $237,945, $457,955, and $172,586, respectively. All 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, the issue remaining for determination...
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