Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rule 180 et seq. All section references are to the Internal Revenue Code as amended and in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner's Federal income tax for 1987 in the amount of $6,794.00 and an addition to tax under section...
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