MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1993 and 1994 in the amounts of $4,084 and $2,561, respectively. Respondent also determined accuracy-related penalties under section 6662(a) for negligence or...
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