Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the year 1987 in the amount of $5,062 and for the year 1988 in the amount of $31,853.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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