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 1982 and 1983 in the amounts of $802 and $595, respectively. Petitioner resided in Columbia, South Carolina when he filed his petition with this Court...
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