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 April 12, 1993, respondent determined a deficiency in petitioners' 1989 Federal income tax in the amount of $4,639 and an addition to tax pursuant to section 6651(a) in the amount of $696. Petitioners, residents of Downsville, Louisiana, filed...
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