MEMORANDUM OPINION
DEAN, Special Trial Judge:
These consolidated cases were assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' 1990 and 1991 Federal income taxes in the amounts of $6,871 and $632, respectively, and an accuracy-related penalty under section 6662(a) for the taxable year 1990 in the amount of $1,374.
After concessions...
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