Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined a deficiency of $4,647 in petitioner's Federal income tax for taxable year 1986, together with additions to tax for negligence under section 6653(a)(1)(A) and (B) in the respective amounts of $14 and 50 percent of the interest due on the portion of the...
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