Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d)(3) of the Code (redesignated sec. 7443A(b)(3) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181 and 182.
Respondent determined a deficiency in petitioner's 1982 Federal income tax in the amount of $1,726. After concessions by both parties,
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