Memorandum Opinion
PANUTHOS, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) of the Internal Revenue Code of 1986. This case is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief can be granted. Respondent, in his notice of deficiency dated August 26, 1988, determined a deficiency for the taxable year 1983 in the amount of $6,432. Respondent further determined additions to tax as follows...
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