Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1988 in the amount of $13,233 and an addition to tax for negligence under section 6653(a)(1) in the amount of $662.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year before the Court, and all Rule references are to the Tax Court Rules of Practice...
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