Memorandum Findings of Facts and Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent issued a notice of deficiency to petitioners in which he determined a deficiency of $5,289 in their Federal income taxes for 1985. After concessions by both parties, the issues remaining for our decision are: (1) Whether petitioners were engaged...
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