Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in and additions to petitioner's income tax as follows:
IRC 1954, Year Deficiency Sec. 6653(a) 1978 .............. $3,605.77 $180.29 1979 .............. 9,427.97 471.40 1980 .............. 6,082.82 304.15
After concessions, the issue...
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