Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181 and 182.
Respondent determined a deficiency of $7,536 in petitioners' Federal income tax for the taxable year 1987, and additions to tax under section 6653(a)(1)(A) and (B).
After concessions by respondent, the only issue for decision is whether petitioners were qualified individuals...
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