Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's 1981 income tax in the amount of $19,061 and additions to tax for that year as follows:
IRC, 1954 Amount Sec. 6651(a)(1) $2,701.75 Sec. 6653(a)(1) 953.05 Sec. 6653(a)(2) 50 percent of the interest due on $19,061
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