MEMORANDUM OPINION
WELLS, Judge:
Respondent determined deficiencies in income tax and additions to tax pursuant to sections 6651(a)(1) and 6654 for petitioner's taxable years 1997 and 2002 as follows:
Year Deficiency Sec. 6651(a)(1) Sec. 6654 1997 $1,991 $497.75 $106.50 2002 7,666 479.50 N/A
Unless otherwise indicated, all section references are to...
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