PEEPLES v. COMMISSIONER

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, section 1556, 100 Stat. ___) and Rules 180, 181 and 182.1

Respondent determined the following deficiencies in an additions to petitioner's Federal income and self-employment taxes for the years 1982 and 1983:

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