MEMORANDUM OPINION
PAJAK, Special Trial Judge.
Respondent determined deficiencies in petitioners' Federal income tax in the amounts of $2,293 and $1,815 for the taxable years 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.
In an amended answer, respondent claimed an increased...
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