Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986,
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1983 and 1984 in the amounts of $2,292.04 and $1,395.04, respectively. After concessions by the parties, the sole issue is whether petitioners...
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