Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income taxes for 1976 and 1977 as follows:
Additions to Tax, I.R.C. 19541 Sec. Sec. Sec. Year Deficiencies 6651(a) 6653(a) 6654 1976 .... $12,441 $3,110 $622 $464 1977 .......
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