Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $30,826 in petitioner's Federal income taxes for 1988 and additions to tax of $6,936 under section 6651(a)(1), $7,707 under section 6651(a)(2), and $7,707 under section 6661. 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...
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