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 1992 Federal income tax in the amount of $5,890 and additions to tax under sections 6651(a)(1) and 6654 in the amounts of $1,257 and $241, respectively.
After a concessions by the parties,
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