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 a deficiency in petitioner's 1986 Federal income taxes of $6,515, and additions to tax for negligence under section 6653(a)(1)(A) of $326, and under section 6653(a)(1)(B) in an amount equal to 50 percent of the interest due on $4,915...
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