MEMORANDUM OPINION
HALPERN, Judge:
By notice of deficiency dated September 21, 1995, respondent determined the following deficiencies in petitioners' Federal income taxes:
Tax Year Deficiency 1990 ........................... $35,219 1991 ........................... 60,129 1992 ........................... 66,435
After concessions, the only issue is whether payments received by...
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