MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, 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' Federal income tax for the taxable year 1990 in the amount of $6,169.
After concessions by the parties, the issues remaining for decision are: (1) Whether an advance by petitioner Billie Lykins...
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