Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A by the Tax Reform Act of 1986, Pub.L. 99-514, section 1556, 100 Stat. ___) of the Code
Respondent issued two notices of deficiency in which the following deficiencies in Federal income taxes and additions to tax were determined...
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