MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated May 20, 2003 (the notice), respondent determined a deficiency in petitioner's 2000 Federal income tax of $26,436 and additions to tax of $4,817, $2,248, and $1,121 under sections 6651(a)(1) and (2) and 6654(a), respectively. Petitioner assigned error to each of those determinations. Respondent conceded the addition to tax determined under section 6651(a)(2) and asserted...
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