Memorandum Findings of Fact and Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to section 7443A(b) of the Internal Revenue Code and Rule 180 et seq.
Respondent determined a deficiency in petitioner's Federal income tax for the year 1984 in the amount of $5,860; an addition to tax under section 6661 in the amount of $1,259.50; an addition to tax under section 6653(a)(1) in the amount of $251...
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