MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673.
Respondent determined a deficiency of $22,285 in petitioner's 1998 Federal income tax, a section 6651(a)(1) addition to tax of $10,585.38, and a section 6654(a) addition to tax of $1,011.45. In his answer, respondent adjusted the amount of the section 6651(a)(1) addition...
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