MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice of deficiency dated May 11, 2001, respondent determined an $891 deficiency relating to petitioner's 1998 Federal income taxes. The sole issue for decision is whether petitioner is liable, pursuant to section 1401,
FINDINGS OF FACT
In 1998, petitioner was a full-time police officer for the Tallahassee Police Department ...
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