Memorandum Findings of Fact and Opinion
PETERSON, Chief Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182. 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 the year 1986 in the amount...
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