MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Robert M. Garner petitioned the Court to redetermine respondent's determinations of additions to his 1982 Federal income tax. Respondent determined that petitioner was liable for a $487 addition to tax for negligence under section 6653(a)(1) and a $2,924 addition to tax for valuation overstatement under section 6659(a). Respondent also determined that...
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