Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Additions to Tax Year Deficiency Sec. 6653(b)...1 Sec. 6654 1980... $14,533.00 $7,266.00 $794.00 1981... $15,062.00 $7,531.00 $472.00
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