Memorandum Findings of Fact and Opinion
AARONS, Special Trial Judge:
This case was heard pursuant to section 7456(d)(3) of the Internal Revenue Code and Rules 180, 181 and 182 of the Tax Court's Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners' Federal income tax for the year 1980 in the amount of $5,947, with additions to tax under sections...
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