MEMORANDUM OPINION
CARLUZZO, 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' 1992 Federal income tax in the amount of $3,471, and an accuracy-related penalty under section 6662(a) in the amount of $694. Following concessions by respondent, the issues for decision are: (1) Whether petitioners properly...
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