Memorandum Opinion
KÖRNER, Judge:
In these consolidated cases, respondent determined deficiencies of income tax and additions to tax against petitioner, in the amounts and for the years as follows:
Additions to Tax Docket No. Tax Year Ended Deficiency 6651(a)1 6653(a) 6654 15232-82 Dec. 31, 1978 ....... $3,020.00 ...
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