MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY,
This case is before the Court on a petition for redetermination of an income tax deficiency of $111,404.68, an $18,620.17 addition to tax under section 6651(a)(1) for failure to timely file a Federal income tax return, and a $22,280.94 section 6662(a) accuracy-related penalty for the 2007 taxable year.
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