Memorandum Opinion
WOLFE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $4,698 in petitioner's Federal income tax for 1991 and additions to tax for that year in the amount of $804 under section 6651(a) for failure to file a timely Federal income tax return and in the amount of $51 under section 6654 for failure...
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