MEMORANDUM OPINION
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's Federal income tax for 1994 in the amount of $2,872, an addition to tax pursuant to section 6651(a)(1) in the amount of $718, and an addition to tax pursuant to section 6654(a) in the amount of $147.99.
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