Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated April 15, 1982, respondent determined that petitioner is liable for deficiencies and additions to tax as follows:
Addition to tax under Year Deficiency Sec. 6653(b) Sec. 6654 1978...... $2,467.00 $1,233.50 ..... 1979...... 2,421.00 1,210.50 $ 83.98 1980...... 3,387.00 1,693.50 215...
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