Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency with respect to petitioner's 1980 Federal income tax of $10,645.55 and an addition to tax under section 6653(b) of $5,322.78. The issues are (1) whether respondent's motion to dismiss for failure to properly prosecute should be granted; (2) whether petitioner is liable for an addition to tax for fraud under section 6653(b)
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