Memorandum Opinion
GUSSIS, Special Trial Judge.
This case was heard pursuant to the provisions of 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 1988 in the amount of $2,452. The issue for decision is whether petitioner...
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