Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner's Federal income taxes for the taxable years 1979, 1980, and 1981 in the amounts of $5,127, $6,856, and $1,731, respectively. The Commissioner also determined that there are additions to tax for the taxable years 1979, 1980, and 1981 under sections 6651(a),
Year...
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