Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1977 in the amount of $434. The issues for decision are (1) whether the deficiency determined by respondent is invalid because petitioner's return was selected for examination on an improper basis; and (2) whether petitioner was subjected to an unnecessary examination or an improper second inspection of her books and records...
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