MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, 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 for the taxable year 1992, as well as an accuracy-related penalty for negligence under section 6662(a), in the amounts of $6,176 and $1,235, respectively.
Respondent subsequently...
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