MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge:
Respondent determined a deficiency in petitioner's Federal income taxes for the calendar year 1990 in the amount of $14,432, and an accuracy-related penalty under section 6662
Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for decision: (1) Whether this Court has jurisdiction over this...
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