Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated May 16, 1980, respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Addition to tax Taxable pursuant to sec. year ended Deficiency 6651(a)(1) Sept. 30, 1976 $29,290 $7,322.50 Sept. 30, 1977 5,626 1,406.50
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