MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the fiscal year ending February 28, 1995, in the amount of $1,576 and a section 6662(a) penalty in the amount of $315.20. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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