MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated April 21, 1999, respondent determined the following deficiencies relating to petitioners' Federal income taxes:
Reginald and Ronda Charlson, Docket No. 12840-99
Year Deficiency 1994 ................... $125,027 1995 ................... 26,775 1996 ................... 30,058...
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