Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
By notice of deficiency dated October 19, 1984, respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows:
Addition to tax under Year Deficiency Section 6651(a)(1)1 1979 $12,269 -- 1980 57,637 $11,046 1981 29,454 ...
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