MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, 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 in petitioner's 1992 Federal income tax in the amount of $1,350 and a section 6662(a) accuracy-related penalty in the amount of $270. The deficiency and related penalty result entirely from the imposition of the section...
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