MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge.
Respondent determined a deficiency in petitioner's Federal income tax for 1989 of $59,718. Respondent also determined the following: (1) an addition to tax of $3,076 under section 6651(a)(1); (2) an accuracy-related penalty of $11,944 under section 6662 due to a substantial understatement of income tax, and (3) an addition to tax of $4,182 under section 6654(a) as a result of the failure of petitioner...
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