Memorandum Opinion
NAMEROFF, Special Trial Judge:
These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
In docket No. 190-94, respondent determined deficiencies in the individual petitioners' Federal income taxes for 1988 and 1989 in the respective amounts of $1,904 and $2,452. Respondent also determined an addition to tax under section 6653(a) in the amount...
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