Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's 1977 and 1978 Federal income taxes in the amounts of $8,053 and $3,600, respectively. Respondent also found that petitioner was subject to additions to tax for negligence under section 6653(a), and an increased...
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