Memorandum Findings of Fact and Opinion
CANTREL, Special Trial Judge:
This case was assigned and heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 183.
In his joint notice of deficiency issued to petitioner and Donna L. Powers (Ms. Powers), respondent determined a deficiency in their Federal income tax for the calendar year 1986 in the amount of $324.
The issue for decision...
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