MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency in Federal income tax of $2,929.75 and the addition to tax under section 6651(a)(1) in the amount of $732.43 for petitioner's 1988 tax year.
The issues for decision are: (1) Whether petitioner is entitled, under section 162(a), to cost of goods...
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