MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge:
In these consolidated cases respondent determined the following deficiencies in petitioners' Federal income taxes:
Petitioners Docket No. Year Deficiency Zahirudeen and Carol M. Premji ..................... 8372-94 1990 $18,501 Carl John Norby .................................... 10353-94 1990...
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