Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Additions to tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) 1984 ... $3,230 $161.50 * 1985 ... 2,757 137.85 * * 50 percent of the interest due...
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