Memorandum Findings of Fact and Opinion
LARO, Judge:
This case is before the Court pursuant to a petition filed by Herman Finesod (petitioner) for a redetermination of respondent's determination of deficiencies in petitioner's 1977 through 1980 Federal income taxes, additions to those taxes under sections 6651(a) and 6653(a), and an increased interest rate under section 6621(c) with respect to the portion...
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