Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiency and additions to tax in petitioner's Federal income taxes:
Additions to tax Year Deficiency Sec. 6653(b)(1)1 Sec. 6653(b)(2) Sec. 6654 1982 ............... $5,220.54 $2,840 50% of the...
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