Memorandum Opinion
CANTREL, Special Trial Judge:
This case was assigned pursuant to section 7443A(b)(3), I.R.C. 1986, and Rules 180, 181, and 182, and submitted under Rule 122.
In the notice of deficiency issued to petitioner, respondent determined deficiencies in Federal income taxes and additions to tax for the calendar years 1968 through 1970 in the following respective amounts:
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