Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Docket No. 31027-87 Additions to Tax Year Deficiency Sec. 6653(a) 1977 .............. $25,915.03 $1,060.60 1978 .............. 24,307.29 1,215.36 1979...
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