MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a $71,652 deficiency in petitioner's Federal income tax for 1993. Respondent also determined that petitioner is liable for additions to tax for 1993 of $12,425 for failure to file a timely return under section 6651(a), and $1,980 for failure to pay estimated tax under section 6654(a).
Respondent now concedes that petitioner overpaid his 1993 Federal income tax by $6,267...
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