MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
Petitioner petitioned the Court to redetermine respondent's determinations of deficiencies in petitioner's 1994, 1995, and 1996 Federal income taxes and additions thereto. These determinations are as follows:
Additions to Tax Years Deficiencies Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654...
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