Memorandum Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies for 1982 and 1983 in the respective amounts of $6,239.46 and $13,523.25 against petitioners, husband and wife, who had filed joint returns for those years. Although there was only a single deficiency notice for the two years, separate petitions were filed in respect of each year, and the petition for 1982 was filed as a small tax ("S") case. Thereafter, pursuant to motion...
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