MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for 1996 of $3,548 as well as additions to tax under section 6651(a)(1) of $887 and section 6654 of $189.
The issues for decision are: (1) Whether petitioner received $15,800 of unreported income in 1996 as respondent determined; and (2) whether petitioner is liable for additions to tax under sections...
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