MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
These consolidated cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners James and Barbara Brooks' 1993 Federal income tax in the amount of $5,214. Respondent determined a deficiency in petitioner John J. McMahon's 1992 Federal income tax in the amount of $5,115.
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