SMITH v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

PARR, Judge:

Respondent determined deficiencies in, and additions to tax on, petitioner's Federal income tax for the taxable years 1992, 1993, and 1994 as follows:

                                          Additions to Tax
Year                         Deficiency   Sec. 6651(a)(1)

1992 .....................     $4,073         $1,018
1993 .....................      4,219 ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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