Memorandum Findings of Fact and Opinion
COHEN, Judge:
In statutory notices sent May 25, 1990, respondent determined deficiencies of $15,167, $15,195, and $20,463 in petitioner's Federal income taxes for 1985, 1986, and 1987, respectively. Respondent also determined that petitioner is liable for additions to tax under section 6651(a) for failure to file timely returns, under section 6653(a) for negligence, and under section 6654(a) for failure to pay estimated...
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