Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was assigned to the undersigned pursuant to the provisions of section 7456(d)(3) of the Code (redesignated sec. 7443A(b)(3) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. —) and Rules 180, 181 and 182.
Respondent determined a deficiency in petitioners' 1979 Federal income tax in the amount of $3,186. Petitioners resided at Fountain...
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