United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Year Deficiency 1991 $51,441 1992 33,549 1993 49,210
Unless otherwise indicated all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issues...
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