COTTRELL v. COMMISSIONER

Memorandum Findings of Fact and Opinion

CANTREL, Special Trial Judge:

This case was assigned and heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 183.1

In his joint notice of deficiency issued to petitioners, respondent determined a deficiency in petitioners' Federal income tax and additions to tax for the calendar year 1987 as follows:

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