Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $9,706 and $7,097 in petitioner's Federal income taxes for 1982 and 1983, respectively, and additions to tax for fraud under section 6653(b)(1) and (2) and for underpayment of estimated tax under section 6654 for each year. In the answer, respondent alleged, in the alternative, that petitioner was liable for additions to tax under section 6651(a)(1) for failure to...
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