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 1994 and 1995 in the amounts of $2,855 and $2,893, respectively, as well an accuracy-related penalty under section 6662(a) for the taxable year 1994 in the amount...
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