MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes for 1989 and 1990 in the respective amounts of $5,952 and $6,471.50, and an accuracy-related penalty under section 6662(b)(1) for 1990 in the amount of $1,294.30.
After concessions,
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