MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
William Allen Simpson petitioned the Court to redetermine respondent's determination of a $43,858 deficiency in his 1994 Federal income tax and additions thereto under sections 6651(a)(1) and 6654(a) of $6,840 and $2,227, respectively. Following the parties' concessions, we must decide whether petitioner may deduct amounts for 1994 greater than those allowed by respondent and whether petitioner is liable...
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