United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
For the taxable year 1991, respondent determined a deficiency in petitioner's Federal income tax in the amount of $3,385 and an accuracy-related penalty under section 6662(a) in the amount of $677.
The issues for decision are as follows:
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