MEMORANDUM OPINION
WELLS, Chief Judge:
Respondent determined deficiencies in the Federal income tax of petitioner Jane Gilbert, formerly Jane Hawley (Ms. Gilbert), for the taxable years 1993, 1994, and 1995 of $7,163, $8,922, and $6,157, respectively. Respondent determined deficiencies in the Federal income tax of petitioner Richard C. Hawley, M.D. (Mr. Hawley), for the taxable years 1993, 1994, and 1995 of $21,644, $23,261, and $19,355, respectively.
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