MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
This case was heard pursuant to section 7443A of the Code and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure. All section references are to the Internal Revenue Code in effect for the years in issue.
Respondent determined deficiencies in petitioner's Federal income taxes for the 1993 and 1994 tax years in the amounts of $1,511 and $2,243, respectively. The 1993 and 1994 deficiency...
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