MEMORANDUM OPINION
KÖRNER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year 1990 in the amount of $10,741.
All statutory references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, except as otherwise noted.
This case was submitted to the Court upon a full stipulation of facts and exhibits without trial...
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