Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1986 Federal income taxes of $1,012, and additions to tax for negligence of $50.60, plus 50 percent of the interest due on $1,012. After concessions by both parties, the issues remaining for our decision...
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