Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiencies in, and additions to, the Federal income tax of petitioner Charles W. Herzog:
Addition to Tax Year Deficiency under Sec. 6653(b)1 1977 ........ $1,630 $ 815 1978 ........ 4,978 2,4892
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