MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Hugh Wilkinson (Dr. Wilkinson) and Evelyn Wilkinson (Mrs. Wilkinson) petitioned the Court to redetermine respondent's determination with respect to their 1988 through 1990 taxable years. Respondent determined and reflected in a notice of deficiency dated November 3, 1995, the following deficiency, additions to tax, and penalties:
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