OPINION
SIMPSON, Judge:
This matter is before us on the Commissioner's motion for judgment on the pleadings. The Commissioner determined deficiencies in the petitioner's Federal income taxes of $2,226.33 for 1975 and $2,980 for 1976 and additions to the tax of $106 and $149, respectively, for such years under section 6653(a) of the Internal Revenue Code of 1954.
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