Memorandum Findings of Fact and Opinion
KöRNER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax as follows:
Additions to Tax Year Deficiency Sec. 6651(a)1 Sec. 6653(a)2 1979 $16,707 $4,177.00 $1,225.00 1980 23,818...
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