Memorandum Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioner's income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(b)1 1977 ......... $ 1,807.60 $ 903.80 1978 ......... 19,747.80 9,873.90
During the years involved, petitioner was a resident of the State of Virginia, but prior...
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