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DAWSON, Judge: This case was assigned to Special Trial
Judge Carleton D. Powell pursuant to section 7443A(b)(3) and
Rules 180, 181, and 182.1 The Court agrees with and adopts the
opinion of the Special Trial Judge that is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge: Respondent determined
deficiencies in petitioner's Federal income taxes and additions
to tax as follows:
Additions to Tax
Taxable Year Deficiency Sec. 6651(a)(1) Sec. 6654
1987 $1,672 $418 $90.35
1988 1,729 432 108.99
1989 1,669 417 112.89
1990 4,017 389 264.50
1991 1,534 384 88.22
At the time of filing the petition, petitioner resided in
Mexico.
The issues are: (1) Whether section 874(a) prevents
petitioner, who submitted a return after respondent prepared
substitute returns but before respondent issued a notice of
deficiency, from receiving the benefit of deductions otherwise
allowable under subtitle A of the Internal Revenue Code, and (2)
whether petitioner is liable for additions to tax pursuant to
sections 6651(a)(1) and 6654.
1 Unless otherwise indicated, section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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