MEMORANDUM OPINION
DINAN, 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' Federal income taxes for 1993 and 1994 in the amounts of $4,972 and $5,465, respectively, and accuracy-related penalties pursuant to section 6662(a) in the amounts of $873 and $1,093, respectively.
The issues for decision...
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