Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated February 26, 1980 respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax for fraud under section 6653(b), I.R.C. 1954:
Addition Year Deficiency to tax under sec. 6653(b) 1971 ......... $406.97 $203.48 1972...
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