MULVANEY v. COMMISSIONER

Memorandum Opinion

PETERSON, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) of the Code and Rules 180, 181 and 182.1

Respondent determined a deficiency in petitioners' 1983 Federal income tax and additions to tax for such year, as follows:

                                        Addition to Tax
                                          I.R.C. 1954
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