MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined the following deficiencies in petitioner's Federal income taxes, additions to tax, and penalties for the years 1989, 1990, 1991, and 1992:
Addition to Tax Penalty Year ...
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