MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $5,440 in petitioners' 1990 Federal income tax.
After a concession by respondent, the issues for decision are: (1) Whether petitioners failed to report miscellaneous income of $3,341 received from the Shaklee Corp. (the corporation) in 1990...
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