Memorandum Opinion
RUWE, Judge.
Respondent determined a deficiency of $18,376 in petitioner's 1990 Federal income tax. Respondent further determined additions to tax pursuant to sections 6651(a) and 6654(a)
After concessions, the sole issue for decision is whether petitioner is entitled to a credit or refund for an overpayment of his 1990 Federal
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