Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Sec. 6653(a)1 Year Deficiency Addition to Tax 1977 ........... $23,406.20 --- 1978 ........... 26,218.47 $1,310.92
After numerous concessions by...
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