Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined the following deficiencies in and addition to petitioner's Federal income taxes:
Addition to Tax Year Deficiency Sec. 6661 1980 ................ $37,142 -- 1981 ................ 30,265 -- 1982 ................ 32,307 $8,077
Unless...
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