MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge:
Respondent determined a Federal income tax deficiency for petitioner's 1997 taxable year in the amount of $13,504 and additions to tax pursuant to section 6651(a)(1) and (2) of $2,506.27 and $2,784.75, respectively, and pursuant to section 6654 of $585.91.
(1) Whether petitioner is liable...
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