MEMORANDUM OPINION
COHEN, Judge:
Respondent determined deficiencies of $20,000.60 and $15,230 in petitioner's Federal income taxes for 1995 and 1996, respectively. Respondent also determined additions to tax for failure to file tax returns under section 6651 and for failure to pay estimated taxes under section 6654(a) for both years. The only bona fide issue for decision is whether a penalty should be imposed against petitioner under section 6673(a)(1)....
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