Memorandum Opinion
SCOTT, Judge:
On November 4, 1977, respondent mailed to petitioner a notice of deficiency determining a deficiency in his Federal income tax for the calendar year 1976 in the amount of $164. Petitioner filed a petition in this case in which he alleged in substance the following errors in respondent's determination:
1. That the United States Tax Court as constituted under Article I is unconstitutional because —
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