MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined deficiencies of $32,199 and $13,464 in petitioner's Federal income tax for the tax years ended July 31, 1992, and July 31, 1993, respectively.
All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise specified.
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