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