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.
Respondent, in his notice of deficiency issued to petitioner on June 8, 1989, determined a deficiency in petitioner's Federal income tax for the calendar year 1986 in the amount of $4,948.
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