MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $900, and an accuracy-related penalty pursuant to section 6662(a) in the amount of $180. With the exception of the section 6662(a) accuracy-related penalty, all...
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