Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a statutory notice of deficiency dated April 13, 1984, respondent determined deficiencies in and additions to petitioner's 1978, 1979, and 1980 Federal income tax liabilities as follows:
Addition to Tax Year Deficiency Sec. 6653(b)1 1978 ............ $ 29,601 $18,441...
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