Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code for the taxable year in question, unless otherwise indicated. All rule numbers refer to the Tax Court Rules of Practice and Procedure.)
Respondent determined a deficiency in petitioners' income tax for 1982 of $2,819 and additions to tax for negligence of...
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