MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $8,913 in petitioner's Federal income tax for 1987 and an addition to tax of $2,228 pursuant to section 6651(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions, the deficiency and the addition...
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