Memorandum Opinion
PANUTHOS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) and Rules 180, 181 and 182.
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1979 in the amount of $6,100 together with an addition to tax under section 6651(a)(1) in the amount of $1,525.
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