MEMORANDUM OPINION
POWELL, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency and an addition to tax under section 6651(a) in petitioner's 1993 Federal income tax in the respective amounts of $425 and $396.05. At the time the petition was filed, petitioner resided in Swainsboro, Georgia.
The only issue is whether petitioner...
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