MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' 1992 and 1993 Federal income taxes in the amounts of $3,570 and $8,526, respectively, and an accuracy-related penalty under section 6662(a) in the amount of $714 for 1992.
The issues for decision are: (1) Whether...
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