Memorandum Opinion
BUCKLEY, Special Trial Judge.
This case was heard pursuant to the provisions of section 7443A(b)(3)
Respondent determined a deficiency in petitioner's 1986 Federal income tax in the amount of $6,178, together with an addition to tax under section 6653(a)(1)(A) in the amount of $309, and under section 6653(a)(1)(B) in the amount of 50 percent of the interest due on $6,178...
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