MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies, additions to tax, and penalties with respect to petitioner's Federal income tax as follows:
Additions to Tax, I.R.C., Sections Year Deficiency 6654 6653(b)(1)(A) 6653(b)(1)(B) 6651(f) 1987 $14,635 $785...
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