Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated March 28, 1979 respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Taxable year Addition to tax ended Dec. 31, Deficiency under sec. 6653(a) 1975 .... $ 6,083.32 $304.16 1976 .... 12,717.95 635...
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