MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $29,262 deficiency in petitioner's 1992 Federal income tax, and additions to tax pursuant to sections 6651(a) and 6654(a) in the respective amounts of $5,725.50 and $966.79.
The issues for decision are: (1) Whether petitioner failed to report income during the year in issue; (2) whether petitioner is liable for a section 6651(a) addition to tax for failure to file a 1992...
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