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 7, 1993, respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1990 in the amount of $2,085 and additions to tax under sections 6651 and 6662(a) in the amounts of $149.60 and $417.33, respectively. Petitioners...
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