MEMORANDUM OPINION
WOLFE, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $7,428 for the taxable year 1996. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions made by respondent, the remaining issues for decision are: (1) Whether petitioner...
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