Memorandum Opinion
POWELL, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
By a notice of deficiency issued on July 11, 1991, respondent determined a deficiency in petitioners' 1988 Federal income tax liability and an addition to tax under section 6653(a)(1)(A) in the respective amounts of $5,988 and $299. Petitioners filed a timely petition with...
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