MEMORANDUM OPINION
COHEN, Judge:
Respondent determined deficiencies and additions to tax as follows:
Additions to Tax, I.R.C. Year Deficiency Sec. 6651(f) Sec. 6654 1996 $9,058 $5,844.75 — 1997 13,485 10,053.75 $716.70 1998 20,731 ...
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