MEMORANDUM OPINION
POWELL, 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 Federal income tax for the taxable year 1989 in the amount of $7,466 and an addition to tax under section 6651 in the amount of $1,866. Petitioner resided in Auburn, California, when he timely filed his petition.
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