OPINION
COHEN, Judge:
Respondent determined a deficiency of $76,146 in petitioner's Federal income tax for 1986. Respondent also determined that petitioner is liable for additions to tax of $19,037 under section 6651(a)(1), $3,807 under 6653(a)(1)(A), $3,684 under section 6654, and 50 percent of the interest due on $76,031 under section 6653(a)(1)(B) for 1986.
Unless otherwise indicated, all section references are to the Internal Revenue Code...
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