MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $858 in petitioner's Federal income tax for 1991.
The issues for decision are: (1) Whether a State income tax refund of $1,738 received by petitioner during 1991 constitutes taxable income for that year; (2) whether petitioner is entitled to...
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