MEMORANDUM OPINION
POWELL, 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 Federal income tax for the taxable year 1992 in the amount of $818. At the time he filed his petition, petitioner resided in Aurora, Colorado.
The sole issue is whether petitioner is required to include in his gross...
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