Memorandum Opinion
POWELL, Special Trial Judge:
This case was heard pursuant to section 7443A.
By statutory notice of deficiency dated October 23, 1990, respondent determined a deficiency in petitioner's Federal income tax for the 1987 and 1988 taxable years in the amounts of $2,219 and $840, respectively. Respondent also determined additions to tax for negligence, in the following amounts:
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