Memorandum Opinion
WHITAKER, Judge:
By statutory notice dated September 18, 1987, respondent determined a deficiency in petitioner's 1982 Federal income tax of $537.48 and an addition to tax for failure to timely file his return of $336.45. Initially, petitioner placed the timeliness of the statutory notice of deficiency in issue. Petitioner failed to reply to respondent's Request for Admissions that the statutory notice was issued prior to the expiration...
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