Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3). All section references are to the Internal Revenue Code as in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioner's Federal income tax for 1984 and 1985, as well as additions to tax, as follows:
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