MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated February 17, 2000, respondent determined deficiencies and section 6651(a)(1) additions to petitioner's Federal income taxes as follows:
Sec. 6651(a)(1) Year Deficiency Addition 1993.............. $269,956 $63,464 1994.............. 502,174 24,859 ...
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