Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax and additions to tax:
Additions to Tax Year Deficiency Sec. 6651(a)1 Sec. 6653(a)1 1974 ... $9,279.43 $2,319.85 $463.97 1976 ... 327.02 81.75 ...
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