Memorandum Findings of Fact and Opinion
NAMEROFF, Special Trial Judge:
This case was heard pursuant to provisions of section 7456(d) of the Code (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 275) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $518. The sole issue for decision is whether...
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