Memorandum Findings of Fact and Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986.
Respondent determined a deficiency of $404 in petitioner's 1982 Federal income tax. Respondent also determined that petitioner was liable for additions to tax under section 6653(a)(1) in the amount of $20.20, and section 6653(a)(2) in an amount...
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