Memorandum Opinion
PATE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) [redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. —] and Rules 180, 181 and 182.
Respondent determined the following deficiency in and additions to petitioner's Federal income tax for the year 1982:
Deficiency ....................... $5,923.00 ...
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