MEMORANDUM OPINION
VASQUEZ, Judge:
Respondent determined the following deficiencies, additions to tax, and penalties in petitioner's 1992 and 1994 Federal income taxes:
Addition to Tax Penalty Year Deficiency Sec. 6651(a) Sec. 6662(a) 1992 ............... $ 4,059 $1,015 $ 812 1994 ............... ...
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