Memorandum Opinion
PANUTHOS, Special Trial Judge:
The proceedings in this case were conducted pursuant to section 7456(d)(3) of the Code (redesignated as section 7443A(b)(3) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1981 and 1982 in the amounts of $4,398.80 and $2,754...
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