MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
This case was assigned 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 $2,506 and an accuracy-related penalty under section 6662(a) in the amount of $501.
The issues for decision...
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