MEMORANDUM OPINION
LARO, Judge:
Respondent determined deficiencies in petitioners Jerome B. and Staci L. Cronin's 1991 through 1994 Federal income tax in the amounts of $7,067, $28,415, $21,134, and $3,506, respectively. Respondent's determination was based on the disallowance of a basis step-up petitioner Mr. Cronin claimed with respect
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