Memorandum Findings of Fact and Opinion
BUCKLEY, 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 $8,549, together with additions to tax under section 6651(a)(1) in the amount of $124.11, and under section 6653(a)(1) and (2)
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