MEMORANDUM 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 deficiencies in petitioner's 1990 and 1991 Federal income taxes in the amounts of $3,919 and $6,376, respectively. Respondent also determined additions to tax for the years 1990 and 1991 under section 6651(a)(1) in the amounts of $540 and $1,594, respectively...
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