Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to section 7443A(b)
Respondent determined deficiencies in petitioners' Federal income taxes of $492, $4,104, $6,073, and $2,247, respectively, for tax years 1982, 1984, 1985, and 1986. As a result of concessions by the parties, there are no issues with respect to the 1986 tax year. The sole issue...
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