MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated August 20, 1998, respondent determined a $23,474 deficiency, and a $4,695 section 6662(a) penalty, relating to petitioner's 1994 Federal income taxes. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions the remaining issues...
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