Memorandum Findings of Fact and Opinion
PARKER, Judge:
By a statutory notice of deficiency dated April 15, 1981, respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Sec. 6653(b)1 Year Deficiency Addition 1972 ........... $19,402.70 $ 9,701.35 1973 ........... 20,281...
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