Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rule 180 et seq.
Respondent determined deficiencies and additions to petitioner's Federal income tax for the years 1979, 1982, and 1983 in three notices of deficiency issued on July 6, 1987, July 8, 1987, and July 27, 1987, respectively, as follows...
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