MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax in the following amounts:
Deficiency Sec. 6651(a)(1) Sec. 6654 1994 ..................................... $1,189 $297 $ 61 1995 ..................................... 2,749 663 143 1996...
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