Memorandum Findings of Fact and Opinion
GERBER, Judge.
Respondent, for petitioner's 1985, 1986, 1987, 1988, 1989, and 1990 taxable years, determined income tax deficiencies in the amounts of $7,515, $7,936, $4,569, $4,666, $3,728, and $4,536, respectively. Respondent also determined additions to tax under section 6651(a)(1)
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