MEMORANDUM FINDINGS OF FACT AND OPINION
POWELL, Special Trial Judge:
This case was assigned pursuant to the provisions of section 443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1992 and 1993 in the amounts of $799 and $791, respectively. Respondent also determined additions to tax pursuant to section 6651(a) in the respective amounts...
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