Memorandum Findings of Fact and Opinion
COHEN, Judge.
Respondent determined a deficiency of $9,196 in petitioner's Federal income tax for 1985 and additions to tax of $2,299 under section 6651(a)(1), $460 under section 6653(a)(1), and $527 under section 6654(a). Respondent also determined an addition to tax under section 6653(a)(2). All section references are to the Internal Revenue Code as amended and in effect for 1985.
After concessions, the issues...
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