Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax as follows:
Addition to Tax Year Deficiency Sec. 6651(a)(1)1 1969 ....... $1,435.50 $358.87 1970 ....... 948.00 237.00
The issues presented for decision are:
(1) Whether payments petitioner received...
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