Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code.
Respondent determined a deficiency in petitioners' Federal income tax for 1984 in the amount of $2,736 and an addition to tax in the amount of $163.80 under the provisions of section 6651(a)(1). Petitioners concede that they failed to report interest income in 1984 in...
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