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 determined deficiencies in petitioners' Federal income taxes of $2,851, $6,194, and $2,070, for the years 1984, 1985, and 1986, respectively. After concessions by both parties, the only issue for our decision is whether petitioner, David W. Marshall...
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