Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) of the Code
Respondent determined a deficiency in petitioner's Federal income tax for the year 1982 in the amount of $5,153, additions to the tax in the amount of $827, under section 6651(a): $258, under section 6653(a)(1); 50 percent of the interest...
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