Memorandum Findings of Fact and Opinion
CANTREL, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1986 Federal income tax in the amount of $7,983, together with additions to tax under section 6653(a)(1)(A) and (B) in the respective amounts of $399.15 and 50 percent of the interest due on $4,901. After concessions,...
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