Memorandum Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
In a notice of deficiency, respondent determined that petitioners were liable for a deficiency in their 1987 Federal income taxes of $9,444, additions to tax for negligence under section 6653(a)(1)(A) of $472, and section 6653...
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