Memorandum Opinion
RUWE, Judge.
Respondent determined a deficiency in petitioner's Federal income tax and additions to tax for the taxable year 1983 as follows:
Additions to Tax Deficiency Sec. 6653(a)(1)1 Sec. 6653(a)(2) Sec. 6654(a) Sec. 6661(a) $171,646.00 ........... $85,823.00 ...
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