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, and Rule 180 et seq. (Hereinafter, all section references are to the Internal Revenue Code of 1954, as in effect in the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure).
Respondent determined the following deficiencies in and...
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