MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $9,161 for 1992, $10,588 for 1993, $9,426 for 1994, and $15,492 for 1995, and additions to tax of $1,095 for 1992, $912 for 1993, $584 for 1994, and $1,362 for 1995 under section 6651(a) for failure to file a timely income tax return.
Respondent concedes that petitioner overpaid Federal income taxes for 1992, 1993, 1994...
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