Memorandum Findings of Fact and Opinion
BUCKLEY, Special Trial Judge:
This case was heard pursuant to section 7456(d) of the Internal Revenue Code (redesignated as sec. 7443A(b) 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 Federal income tax for 1980 in the amount of $4,814.26. Following concessions by petitioner...
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