Memorandum Opinion
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $2,340 in petitioners' Federal income tax for 1990. Petitioners conceded one adjustment in the notice of deficiency — their failure to report $84 interest income on their 1990 Federal income tax return. The sole issue for decision is whether...
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