Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In his notice of deficiency dated January 2, 1978 respondent determined deficiencies in petitioner's income taxes, together with additions to tax, for the following taxable years and in the following amounts:
Sec. 6653(a) Taxable Year Negligence Ended Deficiency Penalty 12/31/74 ...... $2,256.09 $112.80 12/31/75...
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