MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:
Additions to tax Sec. Sec. Year Deficiency 6651(a)(1) 6654 1991........... $ 1,504 $ 376 -- 1992........... 90,846 22,567...
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