Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181 and 182.
Respondent determined deficiencies of $1,756 and $934 in petitioner's Federal income tax for the taxable years 1985 and 1986, respectively, and also determined additions to tax pursuant to sections 6651(a)(1), 6653(a)(1) and 6653(a)(1)(A), and 6653(a)(2) and 6653(a)(1)(B).
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