Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code in effect for the taxable year in issue, unless otherwise indicated. All rule numbers refer to the Tax Court Rules of Practice and Procedure.)
Respondent determined a deficiency in petitioner's 1983 Federal income tax of $103 and an addition to tax under section...
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