Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Additions to Tax Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) 1978 .......................... $29,142.71 $14,571.35 -- 1979 ...............
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