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: (1) A deficiency in Rudolfo A. and Jacalyn Lee Nieto's 1987 Federal income tax of $570; (2) a deficiency in Phillip Louis Johnston's 1987 Federal income tax of $1,165, and an addition to tax for negligence of $58, plus 50 percent of...
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