Memorandum Findings of Fact and Opinion
IRWIN, Judge:
By letter dated September 27, 1978, respondent determined the following deficiencies and additions to tax for fraud pursuant to section 6653(b)
Sec. 6653(b) Year Deficiency addition 1975 ......... $10,169.87 $5,084.94 1976 ......... 7,259.39 3,629.69
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