MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
Respondent determined deficiencies in petitioner's Federal income taxes in the amounts of $2,786 and $3,157 for the taxable years 1995 and 1996. Unless otherwise indicated, 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 for decision for both tax years are: (1) Whether...
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