MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, 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' 1988, 1989, and 1990 Federal income taxes in the amounts of $160, $3,624, and $3,343, respectively. After concessions,
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