Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $13,646 in petitioner's Federal income taxes for 1988 and additions to tax of $10,235 under section 6653(b)(1) and $3,412 under section 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1988, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner failed to appear for trial...
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