Memorandum Opinion
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $1,716 in Federal income tax and an addition to tax under section 6651(a)(1) in the amount of $371 with respect to petitioner's 1990 tax year.
At trial, respondent conceded the deficiency in tax and the addition to tax. The sole issue for decision...
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