MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated September 21, 1992, respondent determined a deficiency in petitioner's 1989 Federal income tax of $26,829. By notice dated December 21, 1992, respondent determined deficiencies in petitioner's 1990 and 1991 Federal income tax of $27,844 and $31,888, respectively. These cases (docket No. 27615-92 for 1988 and docket No. 608-93 for 1990 and 1991) have been consolidated for purposes of trial...
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