MEMORANDUM OPINION
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) (3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for 1992 and 1993 in the amounts of $3,857 and $1,877, respectively, and accuracy-related penalties pursuant to section 6662(a) in the amounts of $771 and $329, respectively.
The issues for decision...
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