MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency of $418 in petitioner's Federal income tax for 1994.
The issues for decision are: (1) Whether petitioner is entitled to a $2,000 deduction for a contribution to an individual retirement account...
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