Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1976 in the amount of $2,474. Petitioners filed a petition in this case in which they alleged that $120.53 of the deficiency determined was in controversy. The petition alleged that the facts upon which they rely as a basis for their case are as set forth in an exhibit attached to their petition consisting of six pages. On February 21, 1978...
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