MEMORANDUM FINDINGS OF FACT AND OPINION
COUVILLION, Special Trial Judge:
These consolidated cases were heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $2,775 in the 1994 Federal income tax of petitioner Irv C. Jaffe (Mr. Jaffe) and a deficiency of $3,431 in the 1994 Federal income tax of petitioner Arlene K. Jaffe (Ms. Jaffe). In an answer to Mr. Jaffe's petition...
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