Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioner's income tax:
Addition Addition to tax to tax Income under Sec. under Sec. Year tax 6651(a)1 6653(a) 1972 ...... $1,703.79 $293.08 $82.32 1973 ...... 1,427.64 .........
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