Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3). All section references are to the Internal Revenue Code as in effect for the year in issue.
In a timely notice of deficiency dated April 23, 1990, respondent determined a $1,112 deficiency in petitioners' 1985 Federal income tax. At trial, respondent orally moved for the imposition of a penalty pursuant to section 6673.
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