Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined an addition to petitioner's income tax for taxable year 1984 in the amount of $110,503 pursuant to section 6651(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue for decision is whether petitioner's failure to timely file...
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