Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rules 180, 181 and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for 1981 and 1982 in the respective amounts of $2,006 and $1,865.60 and an addition to tax under...
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