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