MISLEH v. COMMISSIONER

Memorandum Findings of Fact and Opinion

CANTREL, Special Trial Judge:

This case was assigned and heard pursuant to section 7443A(b)(3) and Rule 180 et seq.1

In his notice of deficiency issued to petitioner on April 24, 1989, respondent determined deficiencies in petitioner's Federal income tax and additions to the tax for the calendar year 1981 in the following respective amounts:

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