MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
By two separate notices of deficiency, respondent determined the following deficiencies in petitioner's Federal income taxes:
Year Deficiency 1989 ........................ $16,263 1990 ........................ 15,814 1991 ........................ 15,994 1992 ........................ 13,469 1993 ........................ 7...
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