LORIN J. v. COMMISSIONER

Memorandum 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 years in issue. All rule numbers refer to the Tax Court Rules of Practice and Procedure.)

Respondent determined deficiencies and additions to tax in petitioners' Federal income tax as follows:

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