Memorandum Findings of Fact and Opinion
ARMEN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1989 and 1990 in the respective amounts of $7,356 and $6,163.
The issues for decision are: (1) Whether the notice of deficiency is invalid because respondent...
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