Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1972 in the amount of $2,267.66. In addition, the Commissioner asserted the negligence penalty pursuant to the provisions of section 6653 (a),1 Internal Revenue Code of 1954, in the amount of $113.38.
Due to concessions, the following issues remain for our decision:
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