MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine respondent's determination of a $47,036 deficiency in his 1998 Federal income tax and additions thereto of $10,279, $2,970, and $2,067 under sections 6651(a)(1) and (2) and 6654(a), respectively.
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