Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) of the Code (redesignated as sec. 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rules 180, 181 and 182.
Respondent determined the following deficiencies in petitioners' Federal income taxes:<...
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