MEMORANDUM FINDINGS OF FACT AND OPINION
GALLOWAY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rules 180, 181 and 182.
Respondent determined deficiencies of $2,823.03, $1,791.84, and $8,731.40 in petitioners' Federal income taxes for 1981, 1982, and 1983, respectively. After concessions, the issue remaining for decision is whether petitioners...
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