MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
In a notice dated December 7, 1996, respondent determined a deficiency, a section 6651(a) addition to tax, and a section 6662(a) penalty relating to Joel Hillman's 1991 Federal income tax. 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. Petitioner resided in Lompoc, California, when he...
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