Memorandum Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1987 Federal income taxes of $780, as well as additions to tax for negligence of $39 and 50 percent of the interest due on the deficiency. The parties have reached an agreement with respect to certain issues which will necessitate...
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