MEMORANDUM FINDINGS OF FACT AND OPINION1
COHEN, Judge.
Respondent determined deficiencies and additions to tax as follows:
AMC Trust, J.O. Haney, Jr., J.O. Haney, III and Patricia A. Haney Trustees (docket No. 22243-03): Additions to Tax/Penalties, I.R.C. Year Deficiency Sec. 6651(a)(1) ...
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