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either section 6651(a)(1) or section 6651(f), and under section
6654 for the years in issue; and (5) whether a penalty should be
awarded under section 6673. Respondent has conceded that
petitioner is not liable for section 6662(a) accuracy-related
penalties as determined in the notice of deficiency for 1989 and
as alleged in the Amendment to the Answer for 1990, 1991, and
1992.
FINDINGS OF FACT2
At the time the petition was filed, petitioner resided in
Crossett, Arkansas. During the years in issue, petitioner was a
veterinarian in a sole proprietorship doing business as the
Crossett Animal Clinic. Petitioner received adjusted gross
income from his veterinary practice of $65,000 in each of the
years in issue. In 1992, petitioner had a short-term capital
gain of $752.50 from the sale of stock. In 1992, petitioner also
received interest income of $35 and dividend income of $65.
Petitioner failed to report the income from his veterinary
practice, the capital gain, or the interest and dividend income,
or to pay Federal income taxes on these amounts. In 1989,
petitioner received a $30,000 premature distribution from his
individual retirement account (IRA).
2 The stipulation of facts and the attached exhibits are
incorporated therein by this reference.
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