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 deficiencies in petitioner's 1994 and 1995 Federal income taxes in the respective amounts of $3,045 and $3,542. Respondent also determined accuracy-related penalties under section 6662(a) for negligence...
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