MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined a deficiency of $8,671 in petitioner's Federal income taxes for 1990 and an addition to tax of $1,746 under section 6651(a)(1). In the answer, respondent asserted that petitioner is liable for a penalty under section 6662(a), either for negligence under section 6662(c) or for substantial understatement under section 6662(d). Unless otherwise indicated, all section references...
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