MEMORANDUM OPINION
CHIECHI, Judge:
Respondent determined the following deficiencies in, and additions to, petitioner's Federal income tax (tax):
Additions to Tax Sec. Sec. Sec. Year Deficiency 6651(a)(1)1 6651(a)(2) 6654(a) 1996 $62,718 $13,661.55 $3,946...
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