MEMORANDUM FINDINGS OF FACT AND OPINION
PARIS, Judge.
Respondent determined deficiencies of $21,456 and $15,290 in petitioner's Federal income tax for 2008 and 2009, respectively. He also determined: (1) section 6651(a)(1) additions to tax of $5,356.25 and $3,245.85 for failure to timely file Federal income tax returns for 2008 and 2009...
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