Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
Respondent determined a deficiency of $4,888 in petitioners' 1981 Federal income tax. (All section references are to the Internal Revenue Code of 1954, as in effect during the taxable years in question, unless otherwise indicated. All rule references are to the Tax Court Rules of Practice and Procedure.)
Prior to trial respondent conceded an Individual Retirement Account issue. The...
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