Memorandum Opinion
COUVILLION, Special Trial Judge:
This case was considered pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $31,099 and $25,145, respectively, for 1977 and 1978. Before the Court is...
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