MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined a deficiency in petitioner's Federal individual income tax for 1994 in the amount of $37,364 and an accuracy-related penalty under section 6662(a) in the amount of $7,472.80.
Unless indicated otherwise, all section references are to the Internal Revenue Code in effect for the year in issue.
After concessions by petitioner, the issues for decision are (1) whether...
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