MEMORANDUM OPINION
GOLDBERG, Special Trial Judge.
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1996 in the amount of $4,391, and additions to tax under sections 6651(a)(1) and 6654 in the amounts of $804 and $164, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
After a concession by petitioner,
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