Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code and Rule 180 et seq.
Respondent determined a deficiency in petitioners' Federal income tax for the year 1980 in the amount of $4,600 and additions to tax under the provisions of section 6653(a) and 6651(a)(1) in the respective amounts of $231.25 and $283.20. Respondent now agrees...
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