Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1987 Federal income taxes of $1,048 and additions to tax for negligence of $52 and 50 percent of the interest with respect to that portion of the underpayment attributable to negligence. The deficiency...
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