Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes for taxable years 1988 and 1989 in the amounts of $7,057 and $7,576, respectively, and an addition to tax under section 6653(a)(1) for taxable year 1988 in the amount of $353.
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