Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
In these consolidated cases, respondent determined deficiencies in petitioner's Federal income tax in the amount of $9,691.67 for taxable year 1980 (Docket No. 10435-84) and $10,588 for taxable year 1981 (Docket No. 20667-85).
After concessions,
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