HALL, Judge:
Respondent determined an $8,356 deficiency in petitioner's 1972 Federal income tax. Respondent also asserted a late filing penalty of $1,453.75 under section 6651(a).
The issues raised are as follows:
(1) Whether petitioner had unreported income in 1972 from the sale of heroin.
(a) Whether respondent's determination was arbitrary and unreasonable.
(b) Whether petitioner is entitled to...
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