Memorandum Opinion
DAWSON, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax:
Addition to Tax Year Deficiency Sec. 6653(a)1 1977 ........... $ 608.00 $30.40 1978 ........... 1,146.00 57.30 1979 ........... 1,202.00 60.10
At issue are (1) whether petitioner has substantiated...
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