MEMORANDUM OPINION
DINAN, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax of $3,240, an addition to tax under section 6651(a)(1) of $162, and an accuracy-related penalty under section 6662(a) of $648, for the taxable year 1996. 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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