MEMORANDUM OPINION
FOLEY, Judge:
In a notice of deficiency issued to Gregory C. Welton on December 13, 1996, respondent determined a $53,692 deficiency in, and a $9,506 section 6662(a) penalty relating to, Mr. Welton's 1994 Federal income tax. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Mr. Welton resided in Solvang, California, at the...
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