MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
By separate notices of deficiency, both dated December 17, 1993, respondent determined the following deficiencies in petitioners' Federal income taxes:
Year Deficiency 1991 ......................... $8,256.75 1992 ......................... 7,810.00
The dispute between the parties concerns the deductibility of losses reported...
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