MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax for the 1990 tax year:
Docket No. Petitioners Deficiency 21366-94 ..................... George and Kathleen Knevelbaard $ 6,592 21981-94 ..................... Wilbur E. and Irene R. Gomes 23,294 22527-94 ..................
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