MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge.
By notice dated April 5, 2005, respondent determined a deficiency in and additions to petitioner's 2002 Federal income tax. The issues for decision are whether petitioner is liable for tax relating to unreported income and for the section 6651(a)(1)
FINDINGS OF FACT
Petitioner is a licensed orthopedic physician. During 2002...
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