MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $25,108 for taxable year 1999 and $19,610.07 for taxable year 2000. Unless otherwise indicated, 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.<...
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