MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $8,936 with regard to petitioner's Federal income tax liability for 1996 and a 25-percent addition to tax under section 6651(a)(1) for failure to file his tax return timely. After a concession by petitioner, the issues for decision are whether petitioner was engaged in the trade or business of recording and producing music during 1996 and whether he is liable for...
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