MEMORANDUM OPINION
DINAN, Special Trial Judge:
These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined additions to petitioners' Federal income taxes for the years as indicated:
Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix, docket No. 16546-96
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