Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax and additions to tax for 1977 and 1978:
Additions to Tax Sec. Sec. Sec. Year Deficiency 6651(a)1 6653(a) 6654 1977 ...... $2,052 0 $102.60 0 1978...
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