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 in the amount of $1,280, an addition to tax under section 6651(a)(1) in the amount of $162, and an accuracy-related penalty under section 6662(a) in...
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