Memorandum Findings of Fact and Opinion
LARO, Judge:
This case is before the Court pursuant to a petition filed by William F. Collins for a redetermination of respondent's determination set forth in her notice of deficiency issued to petitioner on April 6, 1993. For the 1989 taxable year, respondent determined a $21,987 deficiency in petitioner's Federal income tax and a $4,397 addition thereto under section 6662.
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