MEMORANDUM OPINION
DINAN, 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 Federal income taxes for 1991 and 1993 in the amounts of $6,154 and $6,290, respectively, additions to tax pursuant to section 6651(a)(1) in the amounts of $1,539 and $1,573, respectively, and additions to tax pursuant to section...
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