Memorandum Findings of Fact and Opinion
SHIELDS, Judge.
On June 16, 1989 a letter, which with its several enclosures is hereinafter described, was mailed by the office of the District Director, Internal Revenue Service, Omaha, Nebraska, to petitioner. In the letter it is stated that deficiencies in and additions to petitioner's Federal income taxes for 1977 through 1981 had been determined as follows:
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