MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
Respondent determined a deficiency of $211,979 in petitioner D. Richard Ishmael, M.D., PC's 1995 Federal income tax, and a deficiency of $140,025 in petitioner Mid-Del Therapeutic Center, Inc.'s Federal income tax for the taxable year ended April 30, 1995. Both petitioners petitioned the Court to redetermine the respective deficiencies. These cases were consolidated for purposes of trial, briefing, and...
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