Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1982, 1983, and 1984, in the amounts of $7,322, $7,044, and $7,868, respectively. In addition, respondent determined an addition to tax for 1984 of $393 under section 6653(a)(1) and 50 percent of the interest due on $7,868 under section 6653(a)(2).
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