Memorandum Findings of Fact and Opinion
NAMEROFF, Special Trial Judge:
These cases, consolidated for purpose of trial, briefing, and opinion, were heard pursuant to the provisions of section 7443A(b)(3)
In docket No. 26850-90, respondent determined deficiencies in income tax for the taxable years 1981 and 1983 in the amounts of $4,003 and $6,347, respectively...
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