Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies of $20,126 and $11,130 in petitioner's Federal income tax for 1984 and 1985. Respondent also determined additions to tax, as follows:
Internal Revenue 1984 1985 Code Sec. Tax Year Tax Year 6651(a)(1) ................1 $5,032 ...
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