MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency of $14,878 in petitioner's Federal income tax for 1993 and additions to tax under sections 6651(a)(1) and 6654(a) in the amounts of $3,720 and $623, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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