MEMORANDUM OPINION
VASQUEZ, Judge:
Respondent determined a $2,987 deficiency in and a $327.40 penalty pursuant to section 66621 on petitioner's 1999 Federal income tax. On July 15, 2003, respondent filed a motion for sanctions under section 6673.
After concessions, the sole issue for decision is whether to impose a penalty pursuant to section 6673.
Background
Petitioner is 26 years old. In the...
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