MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge.
These consolidated cases involve the following determinations by respondent of deficiencies in petitioners' Federal income tax:
Year Al A. Ruckriegel Sid Paul Ruckriegel 1999 $110,544 $107,064 2000 122,272 124,130
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect...
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