MEMORANDUM OPINION
DINAN, Special Trial Judge:
Respondent determined that petitioner was liable for the following additions to tax for taxable year 1982: $1,070 under section 6653(a)(1), 50 percent of the interest due on a $21,404 deficiency under section 6653(a)(2), and $5,351 under section 6661. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules...
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