MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $9,604 and $6,283 in petitioner's Federal income taxes for 1990 and 1991, respectively. Respondent also determined that petitioner is liable for an addition to tax of $480 under section 6651(a)(1) for 1990 and penalties of $3,842 and $2,513 under section 6662(h) for 1990 and 1991, respectively. The issues for decision are whether petitioner is entitled to various...
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