MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes in the following amounts:
Year Deficiency 1991 ............................. $2,676 1992 ............................. 855 1993...
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