MEMORANDUM OPINION
JACOBS, Judge:
Respondent determined a $34,534 deficiency in petitioner's 1993 Federal income tax and a $6,503 accuracy-related penalty pursuant to section 6662(a).
Following concessions, the issues remaining for decision are: (1) Whether petitioner had $99,880 of unreported income for 1993; and if so, (2) whether petitioner is liable for the section 6662(a) accuracy-related penalty.
All section references are to the Internal...
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