MEMORANDUM FINDINGS OF FACT AND OPINION
CARLUZZO, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986, as amended and in effect at the time the petition was filed, and Rules 180, 181, and 182. Subsequent section references are to the Internal Revenue Code in effect for 1992. Rule references are to the Tax Court Rules of Practice and Procedure.
In a notice of deficiency issued...
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