MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated October 20, 2000 (the notice of deficiency), respondent determined deficiencies in, and additions to, Federal income tax with respect to petitioner John P. Trowbridge (Dr. Trowbridge) as follows:
Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654
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