Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
By notice of deficiency dated January 28, 1985, respondent determined a deficiency of $5,615 in petitioners' 1981 Federal income tax and additions to tax under section 6653(a)(1) and (2) in the respective amounts of $280.76 and 50 percent of the interest due on the amount of...
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