MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined the following deficiencies in, and additions to, petitioner's Federal income tax (tax):
Additions to Tax Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) Sec. 6654(a) 1995 $78,117 $16,573.25 $0 $3,412.62 1996 9,857 642.83 ...
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