Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiency and addition to tax in petitioner's 1982 Federal income tax:
Additions to tax Deficiency Sec. 6653(a)(1)1 6653(a)(2) 6661(a) $8,204 ....... $310.20* $820.40
The issues for decision are ...
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