Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax:
Taxable Year Addition to Tax Ended Deficiency Section 6653(a)1 October 31, 1976... $30,514.99 $1,525.75 October 31, 1977... 34,207.73 1,710.39
Most adjustments in the notice...
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