MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined the following deficiencies with respect to petitioners' Federal income taxes:
Tax Year Deficiency 1989 $94,685 1991 $23,230 1992 $70,009 1993 $38,083 1994 $23,718 1995 $6,039
After concessions, the issues for decision are:
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