Memorandum Opinion1
GERBER, Judge:
This matter is before us to consider respondent's Motion for Judgment on the Pleadings. Respondent in a July 10, 1987, notice of deficiency determined deficiencies and additions to tax for the taxable years 1975 through 1979 as follows:
Addition to Tax- Taxable Year Income Tax Sec. 6653 (b)
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