MEMORANDUM OPINION
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners' 1993 Federal income tax in the amount of $2,380, an addition to tax under section 6651(a) in the...
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