Memorandum Opinion
GOLDBERG, Special Trial Judge.
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' Federal income tax for the year 1986 in the amount of $3,281, as well as additions to tax for negligence in the amounts of $164.05 and 50 percent of the interest on the...
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