MEMORANDUM OPINION
COHEN, Judge:
Respondent determined a deficiency of $169,586 in petitioner's Federal income taxes for 1999 and additions to tax under sections 6651(a)(1), 6651(a)(2), and 6654(a). After concessions, respondent now asserts that petitioner has a deficiency in income tax for 1999 of $24,860 and is liable for an addition to tax under section 6651(a)(1) of $6,215. Respondent concedes that petitioner is not liable for the addition to tax under...
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