Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for 1980 and 1981, and additions to tax, as follows:
Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)1 1980.... $ 7,560.58 $1,432.58 $378.03 1981.... 12,268.93 2,809.96 613.45 ...
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