MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined deficiencies and additions to tax for 1990, 1991, and 1992 with respect to petitioner's Federal income taxes as follows:
Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1990 .............................. $17,238 ...
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