Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d)(3) (redesignated as 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 deficiencies in petitioners' Federal income taxes as follows:
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