Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined a deficiency in petitioner's 1982 and 1983 taxes and additions to tax as follows:
Additions to Tax, Sections1 Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6654 6661(a) 1982 .......... $2,388 $ 597...
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