Memorandum Findings of Fact and Opinion
ARMEN, Special Trial Judge:
This case was heard 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, 1990, and 1991 in the amounts of $2,576, $2,456, and $1,045, respectively.
The issue for decision is whether petitioners are entitled to a deduction...
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