Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in income tax and additions to tax against petitioner as follows:
Additions to tax Sec. Sec. Year Deficiency 6651(a)1 6653(a) 1975 ....... $6,872.20 $1,085.46 $343.60 1976 ....... 6,436.36 1...
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