Memorandum Findings of Fact and Opinion
EKMAN, Judge:
On October 23, 1978, respondent made a termination assessment of income tax under section 6851 in the amount of $20,678.26 for the taxable period January 1, 1978 through October 18, 1978. On May 4, 1979, petitioner filed his income tax return for the year 1978. Respondent subsequently determined a deficiency in petitioner's 1978 income tax of $20,029.69 and an addition to tax under section 6651(a)(1)...
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