Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1976 and 1977 in the amounts of $10,438.90 and $1,008, respectively, and additions to tax under section 6653(a)
The issues for decision are (1) whether petitioner has shown that respondent incorrectly increased his 1976...
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