Memorandum Opinion
GOLDBERG, 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 1989 Federal income tax in the amount of $5,212, and an accuracy-related penalty under section 6662(a) in the amount of $1,042.40.
After concessions by the parties, the issues for decision are whether petitioner...
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