Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $1,762.80 and $2,856.52 in petitioner's Federal income taxes for 1983 and 1984, respectively. Respondent also determined additions to tax of $881.40 and $1,428.26 for fraud under section 6653(b)(1) and claimed an amount under section 6653(b)(2) on the full amount of the deficiencies. Unless otherwise indicated, all section references are to the Internal Revenue Code...
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