MEMORANDUM OPINION
COLVIN, Judge:
Respondent determined that petitioner has an income tax deficiency of $92,384 for 1998 and is liable for an addition to tax under section 6654 of $3,941.12 for failure to pay estimated tax. The matter is before the Court on respondent's motion for summary judgment and motion for a penalty under section 6673.
Background
A. Petitioner
Petitioner was retired and lived in Mississippi...
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