Memorandum Findings of Fact and Opinion
PETERSON, Special Trial Judge:
These consolidated cases were assigned to Special Trial Judge Marvin F. Peterson pursuant to the provisions of section 7456(c) and (d), and General Order No. 8, 81 T. C. XXIII (1983).
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Taxable Year Deficiency 1976 ........................ $3,081.89 ...
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