Memorandum of Findings of Fact and Opinion
WOLFE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) of the Internal Revenue Code.
Respondent determined deficiencies in petitioners' Federal income taxes for 1981 and 1982 in the amounts of $10,925.46 and $8,601.52, respectively.
After concessions, the only issue presented for...
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