MEMORANDUM OPINION
DINAN, 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' Federal income taxes for 1991 and 1992 in the amounts of $2,667 and $3,654, respectively, and penalties for fraud pursuant to section 6663(a) in the amounts of $1,475 and $2...
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