MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined a deficiency of $30,394 in petitioner's Federal income tax for 1991 and an accuracy-related penalty of $6,078 pursuant to section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After a concession by petitioner,...
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