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 a deficiency in petitioner Rose Champy's Federal income tax for the year 1986 in the amount of $1,335 and a deficiency in petitioner Sylvia Champy's Federal income tax for the year 1986 in the amount of $1,336.
Some of the facts have been stipulated...
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