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. Section references are to the Internal Revenue Code in effect for the years 1991 and 1992. Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners' 1991 and 1992 Federal income taxes in the amounts of $1,080 and $1,387...
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