MEMORANDUM OPINION
POWELL, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1994 Federal income tax and an addition to tax under section 6651(a) in the amounts of $4,446 and $126, respectively. Petitioner resided in Guthrie, Oklahoma, when she filed her petition in this case.
The issue is...
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