MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency in petitioner's 2001 Federal income tax and an addition to tax as follows:
Deficiency Addition to Tax Under Sec. 6651(a)(1)* $218,289 $30,739 * Respondent's notice of deficiency also determined additions to tax under secs. 6651(a)(2) and 6654, which additions respondent conceded at trial.
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