OPINION
LARO, Judge:
This case is before the Court on cross-motions for summary judgment. Respondent determined a $28,184 deficiency in petitioner's 1994 Federal income tax and a $5,637 accuracy-related penalty under section 6662(a). Petitioner, while residing in Greendale, Wisconsin, petitioned the Court to redetermine respondent's determination.
Following respondent's concession that petitioner is not liable for the accuracy-related penalty...
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