MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year 1994 in the amount of $11,402 and an addition to tax in the amount of $545 under section 6651(a)(1).
Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references
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