Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge.
This case was assigned pursuant to the provisions of section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code for the taxable year in issue. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.)
Respondent determined a deficiency in petitioners' Federal income tax for 1984 in the amount of $2,347, and additions to tax under...
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