MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax (tax):
Year Deficiency 1992 ............................. $ 265 1993 ............................. 5,116 1994 ............................. 3,094
The issues remaining for decision are:
(1) Did petitioners erroneously include...
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