MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $13,595 and $2,688 for the 1991 and 1992 tax years, respectively.
All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues remaining are (1) whether petitioner
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