MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3)
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1994 in the amount of $6,317 plus additions to tax under section 6651(a)(1) in the amount of $1,579.25 and section 6654(a) in the amount of $325.47. The issues for decision are: (1...
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