Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for taxable years 1986, 1987, 1988, and 1989, in the amounts of $2,004, $1,155, $2,310, and $3,706, respectively. Respondent also determined an addition to tax under section 6651(a)(1) for taxable year 1987 in the amount...
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