Memorandum Findings of Fact and 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 deficiencies in petitioner's Federal income taxes for 1988 and 1990 in the amounts of $2,456 and $3,176, respectively, and additions to tax under section 6651(a)(1) for failure to file timely returns for those years in the respective...
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