Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) of the Code (redesignated sec. 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755), and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' Federal income tax for 1981 in the amount of $3,213, together with an addition to tax under section 6653...
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