Memorandum Opinion
BUCKLEY, Special Trial Judge:
This case was heard pursuant to section 7443A(b) and Rules 180, 181, and 182.
By statutory notice of deficiency respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1988 in the amount of $1,346. Respondent further determined additions to tax for negligence under section 6653(a)(1)...
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