MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner had a deficiency in income tax for 1989 of $78,123, and was liable for an addition to tax of $3,906 under section 6651(a)(1) for failure to file timely and an accuracy-related penalty of $15,625 under section 6662(a) for negligence.
Respondent determined that petitioner received $258,542 in unreported income in 1989 but now concedes that the amount is $218...
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