MEMORANDUM OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1991 and 1992 in the amounts of $7,276.01 and $7,070.43, respectively.
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, unless otherwise indicated.
The issue for decision is whether petitioner is...
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