Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency of $10,325.06 in petitioner's 1971 income tax plus an addition to tax under section 6653(b)
The issues presented for our decision are (1) the extent to which petitioner failed to pay income tax for 1971 and (2) whether any part of the underpayment was due to fraud within the meaning of section 6653(b).
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