MEMORANDUM OPINION
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182. All section numbers refer to the Internal Revenue Code in effect for the taxable year in issue. All rule numbers refer to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner's Federal income tax for the year 1991 in the amount of $4,377, and an addition to tax under section 6651...
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