MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies, additions to tax, and a penalty as follows:
Additions to Tax/Penalty Petitioner Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) Sec. 6662(a) Colin Kelly Kaufman .............. 1992 $25,084 ...
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