MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3)
Respondent determined a deficiency in petitioners' 1994 Federal income tax in the amount of $3,451. This case was submitted fully stipulated, and the sole issue to be decided is whether petitioners are taxable on any amount of Social Security benefits received in 1994. Petitioners...
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