GRUSE v. COMMISSIONER

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 182.1

By separate notices of deficiency dated July 5, 1988, respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:

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