MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's Federal income tax for the year 1989 in the amount of $1,849, an addition to tax in the amount of $241 pursuant to section 6651(a)(1), and an addition to tax of $58 pursuant to section 6654.
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