Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the taxable year 1980 in the amount of $10,515.00; for taxable year 1981 in the amount of $11,493.28; for taxable year 1982 in the amount of $8,445.00; and additions to tax as follows:
Additions to Tax --------------...
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