MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1999 and 2000 in the following amounts:
Petitioners 1999 Deficiency 2000 Deficiency Wortmann $12,864 $12,536 Cain 13,712 10,193 Archbold 18,655 11...
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