MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $62,648 in petitioner's individual 1989 Federal income tax and a $12,530 accuracy-related penalty for negligence under section 6662(a).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1989, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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