MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge:
Respondent determined deficiencies and additions to tax with respect to petitioner's income taxes for 1997, 1998, 1999, 2000, 2001, and 2002 as follows:
Additions to Tax/Penalties Year Deficiency Sec. 6651(a)(1) Sec. 6654 1997 $20,483 $3...
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