REDDICK-STOAKLEY v. COMMISSIONER

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined deficiencies and additions to tax in petitioner's Federal income taxes as follows:

                                        Additions to Tax
  Year                    Deficiency    Sec. 6653(a)(1)1         Sec. 6653(a)(2)

  1983....................  $1,291           $65.00             50 percent of
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