United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's income tax of $13,858 for 1993 and $24,697.91 for 1994, additions to tax for failure to timely file under section 6651(a) of $1,386 for 1993 and $6,175 for 1994, and an accuracy-related penalty of $2,772 for 1993 and $4,939 for 1994 for a substantial understatement of tax under section 6662(a).
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