Memorandum Opinion
PAJAK, Special Trial Judge:
This case was considered pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section numbers refer to the Internal Revenue Code for the taxable years in issue. All Rule numbers refer to the Tax Court Rules of Practice and Procedure. For clarity and simplicity, we have combined the findings of fact and conclusions of law.
Respondent determined deficiencies in petitioners' Federal income taxes...
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