MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $20,596 and $15,803 in petitioner's Federal income tax for the years ended June 30, 1996, and June 30, 1997, respectively. The parties agree that the notice of deficiency contains a mathematical error in the computation of the section 481 tax amount and that the deficiency in dispute is $15,720 for the tax year ended June 30, 1996. The sole issue for decision is whether...
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