Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Taxable Additions to Tax Year Deficiency Section 6653(b)1 Section 6654 1979 ............... $10,461.00 $ 5,231.00 $ 436.00 1980 ................
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