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.
Addition to Tax Penalty Year Deficiency Sec. 6653(a) Sec. 6662(b)(1) 1988 $2,235 $111.75 -- 1989 2,869 -- $236.04
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