MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
These consolidated cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
In separate notices of deficiency, respondent determined a deficiency of $574 in petitioner's Federal income tax for 1992, and a deficiency of $2,719 in petitioner's Federal income tax for 1994, and additions to tax, for 1994, of $429 and $31, under sections 6651(a)(1) and...
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