Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined the following deficiencies in and additions to petitioner's Federal income tax:
Sec. 6653 (a)(1)1 Sec. 6653(a)(2) for 1985 and for 1985 and Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)
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