Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined an addition to tax pursuant to section 6661(a) in the amount of $1,587 with respect to petitioners' Federal income tax...
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