Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) (redesignated sec. 7443A(b) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180 and 181.
By statutory notice respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Year Tax Section...
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