Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, for the taxable years 1978 and 1979, determined deficiencies in Federal income tax in the amounts of $7,918.61 and $7,234.90 and additions to tax under section 6651(a)1 in the amounts of $1,155.33 and $273.34, respectively. By his amendment to answer, filed May 16, 1985, respondent sought an increased deficiency for the taxable year 1979 in the amount of $808...