Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in and additions to petitioner's Federal income tax for the taxable years 1979 and 1980:
Addition to tax Year Deficiency (Sec. 6653(a))1 1979 ......... $15,644.60 $782.23 1980 ......... 17,236.12 861.81
Respondent also determined an...
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