Memorandum Findings of Fact and Opinion
HALPERN, Judge:
Respondent determined deficiencies and an increased rate of interest for petitioner as follows:
Increased Interest Year Deficiency Sec. 6621(c) 1981 $34,073 120% of the interest due on $31,951 1982 16,964 120% of the interest due on $15,855
The sole issue to...
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