Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
By notice of deficiency dated November 20, 1992, respondent determined a deficiency in petitioner's 1988 Federal income tax and additions to tax under sections 6651(a)(1), 6653(a)(1), and 6661(a) in the respective amounts of $5,849, $222.40, $363.15...
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