Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case was assigned and heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
In the notice of deficiency respondent determined deficiencies of $2,648.20 and $352 in income tax for the respective years 1986 and 1987. After...
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