MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $2,171 and an addition to tax pursuant to section 6651(a)(1) in the amount of $540.
Respondent concedes the deficiency and addition to tax in full; thus, the only issue in dispute is...
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