Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:
Additions to Tax Sec. Sec. Year Deficiency 6653(a) 6653(b)1 1973 ........... $5,062.44 ($16.82)2 $2,699.42 1974 ..........
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