MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
Respondent determined a deficiency of $3,832 in petitioner's 1996 Federal income tax and an addition to tax of $952.75 under section 6651(a)(1). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined that petitioner failed...
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