MEMORANDUM FINDINGS OF FACT AND OPINION
PANUTHOS, Chief Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $2,960 for the taxable year 1991. The only issue in dispute is whether petitioners are entitled to claimed dependency exemptions.
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