MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent determined a deficiency in petitioner's 1995 Federal income tax of $37,344, and additions to tax for 1995 for failure to (a) file a return and (b) pay estimated tax. After concessions, the issues for decision are:
1. Whether petitioner's basis in property related to a Chevron gas station business that he sold in 1995 was zero, as respondent contends, or $164,000, as petitioner contends...
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