OPINION
RAUM, Judge:
The Commissioner determined a deficiency in the income tax of Kern County Electrical Pension Fund (petitioner or the pension fund) in the amount of $12,371 for its 1980 taxable year. Petitioner had its principal office in Bakersfield, California, on the date it filed the petition in this case. The case was submitted pursuant to a stipulation of facts and exhibits under our Rule 122.
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