Memorandum Findings of Fact and Opinion
WOLFE, Special Trial Judge:
This case was heard 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 the following deficiencies in, and additions to, petitioner's Federal taxes:
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