MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
Respondent determined the following deficiencies in and additions to petitioner's Federal income taxes:
Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6659(a) 1980 $28,252.46 -- -- 1981 9,478.52 $521.88 $2,843.55
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