MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge:
This case was heard pursuant to section 7443A(b) (3) of the Internal Revenue Code and Rules 180, 181, and 182 of the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $1,451 for the...
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