Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Sec. 6653(a)1 Year Deficiency Addition to Tax 1979 ............... $ 4,867 $243 1980 ............... 10,795 540
After concessions, the issues are (1) whether petitioner is entitled...
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