MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $2,704 in petitioner's Federal income tax, and an accuracy-related penalty of $541 under section 6662(a) for negligence or disregard of rules or regulations for petitioner's 1991 tax year.
The issues for decision are: (1) Whether a golfing activity...
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