MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
By notices dated July 2, 1996, respondent determined deficiencies and additions to petitioners' Federal income taxes as follows:
Nicholas Eustace, Docket No. 21088-96 Year Deficiency 1992 .................... $3,239 Estate of Thomas A. Eustace, Deceased, Vicky Eustace...
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