United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, 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' Federal income tax for the taxable year 1993 in the amount of $2,958.
After concessions by respondent, the issues for decision, which essentially involve substantiation, are as follows:
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