MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent determined deficiencies in petitioner's Federal income tax, penalties, and additions to tax as follows:
Addition to tax and penalties Year Deficiency Sec. 6651(f) Sec. 6654 Sec. 6663 1993 ............ $ 52,022 $38,266.50 $2,137.78 1994 ......
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