MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated October 29, 1998, respondent determined deficiencies of $4,782 and $9,237, and additions to tax, pursuant to section 6651(a)(1), of $530 and $1,882, relating to petitioner's 1993 and 1994 Federal income taxes, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the years in issue, and all Rule references are to the Tax...
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