Memorandum Opinion
DAWSON, Judge:
This case is presently before us on respondent's motion for the entry of a decision pursuant to the Judgment and Opinion of the United States Court of Appeals for the Third Circuit dated April 27, 1982, and the subsequent Order of this Court dated June 14, 1982. The only issues remaining for our decision are whether the petitioner is liable for (1) the additions to tax under section 6651(a)
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