Memorandum Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rule 180 et seq. (Unless otherwise indicated, all section numbers refer to the Internal Revenue Code in effect for the taxable year in issue, and all Rule numbers refer to the Tax Court Rules of Practice and Procedure.)
Respondent determined a deficiency of $2,318 in petitioner's 1986 Federal income taxes.
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