Memorandum Findings of Fact and Opinion
GALLOWAY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1954 and Rules 180, 181, and 182.
By notice of deficiency dated February 28, 1985, respondent determined a deficiency of $5,467 in petitioner's 1981 Federal income tax and additions to tax under sections 6653(a)(1) and 6653(a)(2) in the respective amounts...
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