Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. 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 deficiencies in petitioners' 1985 and 1986 Federal income taxes in the respective amounts of $959 and $4,391. The...
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