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 $6,328 and an addition to tax pursuant to section 6662(a) in the amount of $1,265.60.
After concessions by the parties,
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