Memorandum Opinion
DINAN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rules 180, 181 and 182.
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $907.00 for the taxable year 1982 and $2,658.00 for...
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