MEMORANDUM OPINION
POWELL, Special Trial Judge:
This case was assigned 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 the taxable years 1990 and 1991 in the respective amounts of $4,946 and $6,665, and accuracy-related penalties pursuant to section 6662(a) in the amounts of $989 and $1,333, respectively. At the...
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