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 1992 in the amount of $4,141, as well as an accuracy-related penalty under section 6662(a) in the amount of $828. At trial, respondent asserted an increased deficiency and accuracy...
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