MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated October 7, 2002, respondent determined a deficiency in petitioner's 1999 Federal income tax of $4,616 and an accuracy- related penalty of $923. By the petition, petitioner (1) assigned error to respondent's determinations of a deficiency and a penalty and (2) claimed an overpayment in tax of $3,498. After concessions,
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