MEMORANDUM OPINION
RAUM, Judge:
The Commissioner determined deficiencies in petitioners' 1992 Federal income taxes as follows:
Petitioners Deficiency Ferdinand A. and Marla Morabito ......... $19,462 Joseph J. Chiffone ...................... 13,982 Douglas R. and Joan A. Gamble ........... 30,288 William J. and Roberta E. Prechtl ....... 21,248
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