MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined a deficiency in, and additions to, petitioner's Federal income tax for the taxable year 1988 as follows:
Additions to Tax --------------------------- Year Deficiency Sec. 6651(a)(1) Sec. 6654 1988 $98,917 $24,729.25 $6,326.15
After concessions by the parties...
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