Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner's Federal income tax for tax year 1988 in the amount of $6,885, an addition to tax under section 6651(a)(1...
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