Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $31,147 in petitioner's Federal income tax for 1984 and additions to tax under sections 6651(a)(1), 6653(a)(1) and (a)(2), and 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the year in issue. Respondent has now conceded that petitioner is not liable for the additions to tax under sections 6653...
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