MEMORANDUM OPINION
FOLEY, Judge:
Respondent determined a deficiency in petitioner's 1991 Federal income tax of $24,022 and additions to tax, pursuant to sections 6651(a) and 6654(a), of $6,003 and $1,380.82, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. At the time the petition was filed, petitioner...
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