United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge:
This case was assigned 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 1990 in the amount of $1,791. At the time the petition was filed, petitioner resided in Las Vegas, Nevada.
After concessions,
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