Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
By separate notices of deficiency, respondent determined deficiencies in petitioners' Federal income taxes for taxable years 1988 and 1989 in the amounts of $926 and $3,048.98, respectively.
After concessions and our order granting petitioners partial summary judgment...
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