Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) of the Code
Respondent determined a deficiency in petitioners' Federal income tax for 1980 in the amount of $2,774, and an addition to tax under section 6653(a) in the amount of $138.70. The issues for decision are whether petitioners are entitled to...
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