United States Tax Court.
Memorandum Findings of Fact and Opinion
FAY, Judge:
By notice of deficiency dated February 27, 1984, respondent determined a deficiency of $1,726 in petitioner's 1980 Federal income tax. The issue is whether a Form 433-D (Installment Agreement) executed by petitioner on March 10, 1983 constitutes a closing agreement under
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