MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for their separate taxable years ending September 30, 2000, as follows:
Petitioner Deficiency LOAD, Inc. $16,589 COAD, Inc. $23,954
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
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