Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's Federal income tax for 1988 in the amount of $3,371.
The issue for decision is whether petitioner has taxable income resulting from the payment pursuant to a notice of levy of the balance of his Individual Retirement...
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