MEMORANDUM OPINION
DINAN, Special Trial Judge:
Respondent determined that petitioner was liable for the following additions to tax for taxable year 1982: $452.25 under section 6653(a)(1), 50 percent of the interest due on a $9,045 deficiency under section 6653(a)(2), and $2,261.25 under section 6661. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
The issues for decision are: (1) Whether...
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