Memorandum Findings of Fact and Opinion
PETERSON, Chief Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Findings of Fact
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year...
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