MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a deficiency in petitioner's 1990 Federal income tax in the amount of $22,750 and additions to tax pursuant to sections 6651(a) and 6654(a) in the respective amounts of $5,553 and $1,491.
The issues for decision are:
(1) Whether petitioner had unreported income for the year 1990, as determined by respondent. We hold she did.
(2) Whether petitioner is liable...
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