Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax against petitioner:
Additions to Tax Taxable Deficiency Sec. Sec. Year in Tax 6651(a)1 6653(a) 1975 ........... $3,295.94 none $164.80 1976 ........... ...
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