MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $7,131, an addition to tax under section 6651(a)(1) of $1,198, and an addition to tax under section 6654 of $239 for the taxable year 1996. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
At trial, respondent conceded the section 6651(a)(1) addition to...
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