Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code for the taxable year in issue. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.)
Respondent, in the notices of deficiency, determined overpayments in petitioners' Federal income tax for 1981 and 1982 of $2,097.50 and $78.00, respectively...
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