Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax against petitioner:
Addition to Tax, I. R. C. 1954, Year Deficiency Section 6653(b) 1979 .......... $3,570.93 $1,785.47 1980 .......... 8,323.83 4,161.92 1981...
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