Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) of the Code
Respondent determined a deficiency in petitioner's Federal income tax for 1982 in the amount of $1,553.83, and additions to tax under sections 6651(a), 6653(a)(1), and 6654 in the amounts of $388.46, $77.69,
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