CURMON v. COMMISSIONER

Memorandum Opinion

PAJAK, Special Trial Judge.

This case was assigned pursuant to the provisions of section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code for the taxable year in issue, unless otherwise indicated. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.)

Respondent determined a deficiency in and additions to petitioner's Federal income tax for 1984 as follows:

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