Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following deficiencies and additions to tax in petitioner's Federal income taxes:
Addition to tax1 Year Deficiency Section 6653(a) 1974 ........... $3,197.85 $159.89 1975 ........... 2,479.14 123.96
The issues for decision are:
(1) Whether petitioner...
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