MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Estate of Irving Nemerov, Deceased, Bernice Midgorden, Personal Representative, petitioned the Court to redetermine respondent's determination of a deficiency in its Federal estate tax, and additions thereto under section 6651(a)(1) and (2). Following concessions by the parties, we must decide whether the estate is liable for the additions to tax under section 6651(a)(1) and (2). We hold it is.
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