MEMORANDUM FINDINGS OF FACT AND OPINION
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1991 in the amount of $10,004 and additions to the tax under section 6651(a) in the amount of $1,091.25 and under section 6654(a) in the amount of $214.96.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year before the Court, and all Rule references...
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