MEMORANDUM OPINION
POWELL, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioner's 1990 Federal income tax and an addition to tax under section 6651(a)(1) in the respective amounts of $5,137 and $664. Petitioner resided in Huntsville, Alabama, at the time...
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