MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $5,639 in petitioners' 1988 Federal income tax, and an addition to tax under section 6653(a)(1) in the amount of $281.95.
After concessions,
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