Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined that petitioners are liable for an addition to tax under section 6659(a) for the year 1983 in the amount of $12,110.70.
This case was calendared for trial at the May 17, 1993, trial session of the Court in San Francisco, California. On April 22...
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