Memorandum Opinion
GOLDBERG, Special Trial Judge.
This case was heard pursuant to the provisons of section 7456(d)(3) of the Internal Revenue Code of 1954 (redesignated section 7443A(b)(3) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.
Respondent determined a deficiency of $427.00 in petitioners' Federal income tax for 1981. The only issue for decision is whether petitioner...
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