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 the year 1987 in the amount of $2,453 and additions to tax pursuant to section 6653(a)(1)(A) in the amount of $123, plus 50 percent of the interest payable under section 6601 with respect to the portion...
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