Memorandum Findings of Fact and Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue of Code of 1986 and Rules 180, 181 and 182.
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1984 of $3,442 and additions to tax of $172 under section 6653(a)(1) and an amount to be determined under section 6653(a)(2)....
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