Memorandum 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 issued on June 19, 1992, respondent determined a deficiency in petitioner's Federal income tax in the amount of $1,140 for the taxable year 1989. At the time the petition was timely filed, petitioner resided in Metairie, Louisiana.
The issue...
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