Memorandum 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 deficiencies in petitioners' 1982 and 1983 Federal income taxes of $1,615 and $1,969, respectively. After concessions by petitioners the only...
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