MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
In a notice of deficiency dated July 19, 1996, respondent determined deficiencies in petitioners' Federal income tax for 1992 and 1993 in the amounts of $28,507 and $13,643, respectively. The deficiencies stem from the disallowance of rent paid by Wysong Medical Corp. (Wysong Medical), a subchapter S corporation, to Wysong Corp., a subchapter C corporation, and a corresponding increase in the amount of...
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