Memorandum Findings of Fact and Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986.
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1980 and 1981 in the amounts of $395 and $318, respectively. Respondent also determined that petitioner was liable for additions to tax for 1981 under...
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