Memorandum Findings of Fact and Opinion
PANUTHOS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
In his notice of deficiency dated October 6, 1989, respondent determined a deficiency in petitioner's Federal income taxes for 1982 in the amount of $3,794 and an addition to tax under section 6651(a)(1) in the amount of $507. The issues for decision are...
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