Memorandum Opinion
KÖRNER, Judge:
Respondent determined deficiences in income tax and additions to tax against petitioner for the calendar years 1977 and 1978 as follows:
Additions to Tax Income Section Section Years Tax 6651(a) 6653(a)1 1977 ....... $6,897 $ 86.75 $360.15 1978 ....... 7,056 710.10 686.25
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