Memorandum Opinion
DINAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1990 Federal income tax in the amount of $2,411 and additions to tax under section 6651(a) and section 6654(a) in the amounts of $602.75 and $158.55, respectively.
The issues for decision are: (1) Whether petitioner...
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