ENGLISH v. COMMISSIONER

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d)(3) of the Internal Revenue Code of 1954 and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure.1

Respondent determined a deficiency in petitioner's Federal income tax and additions to tax for the taxable year 1982 as follows:

Income Tax .............           $4,008.00...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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