Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $61,664 in petitioner's Federal income taxes for 1981, additions to tax of $3,083 under section 6653(a)(1), 50 percent of the interest due on the full amount of the deficiency under section 6653(a)(2), and additional interest under section 6621(d). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue....
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