Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986.
Respondent determined a deficiency of $7,090.92 in petitioners' 1985 Federal income tax, the addition to tax for negligence under section 6653(a)(1) and (2) of $354.55 and 50 percent of the interest due on $7,090.92, respectively, and the...
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