Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 Sec. 6659 1980 ........ $7,790.42 $389.52 $ -- 1981 ........ 5,501.00 -- ...
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