Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent, in a statutory notice dated April 8, 1986, determined deficiencies in petitioner's Federal income taxes for 1982 and 1983 and additions to tax as follows:
Additions to Tax Year Deficiency Sec. 66611 Sec. 6651(a)(1) 1982 $13,832.00 $1,383.20 ...
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