Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
The proceedings in this case were conducted pursuant to section 7456(d) (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.
Respondent determined a deficiency in petitioner's Federal income tax for 1982 in the amount of $2,539.40. After concessions by petitioner, the issues...
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