Memorandum Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1989 Federal income tax of $5,968 and an addition to tax pursuant to section 6662 of $1,194. After concessions by respondent (including the addition to tax pursuant to section 6662), the issues for our decision are:
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