MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
In a notice of deficiency dated September 20, 1995, respondent determined deficiencies, an addition to tax, and penalties with respect to petitioner's Federal income taxes as follows:
Penalties Addition to Tax Year Deficiency Sec. 6662(a) Sec. 6651(a)(1) 1991 .... $112,652 $22,530 $5,125...
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