MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined deficiencies of $3,812, $3,588, and $6,222 in petitioner's Federal income taxes for the taxable years 1995, 1996, and 1997, respectively. 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.
After concessions by the parties, this Court must decide...
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