Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income taxes for 1981 and 1982 as follows:
Additions to Tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661 1981 .................... $44,815.35 $2,241
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