Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a notice of deficiency, determined deficiencies in income tax and additions to tax for petitioner, as follows:
Additions to Tax Sec.1 Year Income Tax 6653(a)(1) Sec. 6661 1983 .......... $77,586.49 $3,879.32* ...
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