Memorandum Findings of Fact and Opinion
PETERSON, Chief Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) of the Internal Revenue Code, and Rules 180, 181, and 182. All section references are to the Internal Revenue Code, as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined additions to tax for the taxable years 1982,...
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