MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies of $34,578.07 and $34,855 in petitioner's Federal income taxes for 2001 and 2002, respectively. Respondent also determined that petitioner was liable for additions to tax of $3,344.45 and $1,666.11 under section 6651 and $426.25 and $217.06 under section 6654 for those years, respectively. Because petitioner did not raise any bona fide dispute with respect to...
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