Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined the following deficiency in and additions to petitioner's Federal income tax for 1979:
Additions to Tax Deficiency Sec. 6653(b) Sec. 6654 $44,199.99 $22,100.00 $1,847.72
The issues for decision are:
(1) Whether petitioner had unreported gross income in the amount of $141,952 and taxable income...
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