MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $80,269 in petitioner's Federal income tax and additions to tax of $18,061, $9,632, and $2,684 under sections 6651(a)(1) and (2) and 6654, respectively, for 2002. Respondent conceded the section 6654 addition to tax in respondent's objection to petitioner's motion to amend petition, filed on June 9, 2006.
After concessions by the parties, the issues for decision...
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