Memorandum Findings of Fact and Opinion
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Code and Rules 180, 181, and 182.
Respondent determined a deficiency in income tax for the taxable year 1983 in the amount of $1,786, plus additions to tax pursuant to section 6651(a)(1) in the amount of $1,102
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