Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies and additions to tax in petitioner's Federal income tax for the years 1982 and 1983 as follows:
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