Memorandum Opinion
POWELL, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency and additions to tax under sections 6651(a) and 6653(a)(1) for petitioner's 1988 taxable year in the amounts of $7,270, $145 and $364.
Petitioner filed a timely petition with this Court. At the time the petition was filed...
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