Memorandum Opinion
POWELL, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
By notice of deficiency issued on June 25, 1993, respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $2,735 and an addition to tax for failure to timely file under section 6651(a) in...
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