MEMORANDUM OPINION
NIMS, Judge:
Respondent determined the following deficiencies and additions to tax with respect to petitioner's Federal income taxes for the taxable years 1992 through 1996:
Income Tax Addition to Tax Taxable Year Deficiency Sec. 6651(a)(1) 1992 ............... $4,494 $1,020 1993 ............... 3,757 730 1994 ...........
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