MEMORANDUM OPINION
RUWE, Judge.
This case was submitted fully stipulated. The stipulation of facts, the supplemental stipulation of facts, and the stipulation of settled issues are incorporated herein by this reference.
On November 9, 2001, respondent issued a notice of deficiency determining petitioners owed income tax deficiencies of $17,097, $17,283, and $11,267 for the taxable years 1991, 1992, and 1993, respectively. Additionally, respondent...
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