MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $6,288, plus an addition to tax under section 6654 in the amount of $217 and an accuracy-related penalty under section 6662(b)(1) in the amount of $130.
After concessions by both parties...
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