Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' 1990 and 1991 Federal income taxes in the amounts of $5,751 and $7,253, respectively, and accuracy-related penalties pursuant to section 6662(a) in the amounts of $1,150 and $1,450.60, respectively. Petitioner...
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