Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated March 14, 1978 respondent determined a deficiency in petitioner's income taxes paid for his taxable year ended December 31, 1974 in the amount of $214.58. By letter dated April 13, 1978 respondent determined a deficiency in petitioner's income taxes paid for his taxable year ended December 31, 1976 in the amount of $708.
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