MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined that petitioner is liable for the following deficiency, addition to tax, and penalty for 1990:
Addition to Tax Penalty Deficiency Sec. 6651(a)(1) Sec. 6662 $26,206 .......................... $9,155 $5,241
Unless stated otherwise, all...
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