Memorandum Findings of Fact and Opinion
WOLFE, Special Trial Judge:
Respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $437.
The issues for decision are: (1) whether respondent denied petitioners equal protection under the law by selecting them for audit and issuing them a deficiency notice and, if so, whether the notice of deficiency should be quashed and (2) whether, under section...
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