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 years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in and an addition to petitioner's Federal income tax in the following amounts: for tax year 1988, a deficiency in the amount...
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