Memorandum Opinion
GUSSIS, Special Trial Judge:
These consolidated cases were assigned to Special Trial Judge James M. Gussis pursuant to section 7456(d)(3) of the Internal Revenue Code of 1954 and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners' Federal income taxes for 1982 and 1983 in the amounts of $3,332 and $3,989 respectively. After concessions...
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