Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b). All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners' Federal income tax for 1985 in the amount of $2,152 and in 1986 in the amount of $5,314. The issue presented is whether...
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