Memorandum Opinion
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined deficiencies of $1,147 and $7,842, respectively, in petitioners' Federal income taxes for 1988 and 1989, the addition to tax under section 6653(a)(1) in the amount of $57.35 for 1988, and the penalty under section 6662(a) for 1989 in the amount of $1,568.40 for negligence...
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