Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
By notice of deficiency dated July 20, 1982, in docket No. 25337-82, respondent determined that petitioner was liable for deficiencies in personal income tax and additions to tax under section 6653(b), I. R. C. 1954, for the years 1973, 1974, and 1975 in the following amounts:
Addition to tax under Year Deficiency...
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