Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.
Respondent determined (1) a deficiency in petitioners' Federal income tax for the taxable year 1982 in the amount of $5,365.00, (2) an addition to tax under section 6653(a)(1) in the amount of $268.25,...
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