Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined the following deficiencies and additions to tax in respect of petitioner's Federal income tax for the years 1980 and 1981:
Additions to Tax, I. R. C. 1954 Year Deficiency Sec. 6653(b) Sec. 6654(a) 1980 ......... $4,178 $2,089 $266.20 1981 .......
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