MEMORANDUM OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine respondent's determination of the following additions to its 1989 Federal income tax: A $37,270 addition under section 6651(a)(1), a $42,954 addition under section 6651(a)(2), and a $10,333 addition under section 6655. We decide sua sponte whether we have jurisdiction to decide whether petitioner is liable for these additions to tax. We hold we do not.
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