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 1993 Federal income tax and an accuracy-related penalty under section 6662(a) in the respective amounts of $6,259 and $1,252. Petitioner resided in Walnut Grove, Georgia, at the time the petition was filed.
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