MEMORANDUM OPINION
POWELL, Special Trial Judge.
This case was assigned 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 $2,602. The issue is whether the period of limitations expired before the issuance of the notice of deficiency. Petitioner resided...
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