PER CURIAM:
This appeal attacks the soundness of a memorandum decision of the Tax Court. Finding ourselves in accord with the Tax Court's decision, we append the Tax Court's memorandum opinion.
Affirmed.
MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge:
Respondent determined deficiencies in petitioners' income tax in the amounts and years as follows:
Docket No. Year...
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