Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $69,472.12 in petitioner's Federal income taxes for 1989 and additions to tax of $17,368.03 under section 6651(a)(1) and $4,682.94 under section 6654. After concessions, the issues for decision are whether petitioner is entitled to deduct losses for an alleged horse breeding operation and whether petitioner is liable for the additions to tax determined by respondent...
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