Memorandum Findings of Fact and Opinion
PANUTHOS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined deficiencies in the amounts of $82 and $1,690 in petitioner's Federal income taxes for 1984 and 1985, respectively. Respondent also determined additions to tax for the taxable year 1985 pursuant to section 6653(a)(1) in the amount...
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