MEMORANDUM OPINION
BEGHE, Judge:
Respondent determined the following deficiency in and additions to petitioner's 1991 Federal income tax:
Additions to Tax --------------------------- Deficiency Sec. 6651(a) Sec. 6654(a) $17,391 $3,439 $96
Except where otherwise indicated, all section references are to the Internal Revenue Code in effect for the year...
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