MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioners' 1994 Federal income tax of $12,665 and an addition to tax under section 6651(a)(1) of $1,611.50.
The Xircom company extended a job offer to Shahram Manighalam (petitioner). Petitioner then resigned from a position with his prior employer, American Telephone & Telegraph (AT&T). However, Xircom rescinded its job offer before petitioner...
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