MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge
Respondent determined deficiencies in the Federal income tax of petitioners, William N. Carlstedt and Moira M. Carlstedt, in the amounts of $180,351 and $183,550, for the taxable years ended December 31, 1990, and December 31, 1991, respectively. (The term petitioner will be used henceforth to refer to William N. Carlstedt.)
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