Memorandum Findings of Fact and Opinion
WOLFE, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1983 through 1987 as follows:
Year Deficiency 1983 ............................... $ 989 1984 ..................
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