Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' Federal income tax for 1987 of $3,365 and additions to tax pursuant to section 6653(a)(1)(A) and (B) in the amounts of $168 and 50 percent of the interest due on the underpayment of $3,365, respectively.
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