MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $2,502.
The sole issue for decision is whether benefits received from the U.S. Railroad Retirement Board (USRRB) during the year at issue constitute gross income to petitioners...
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