Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in an April 8, 1986, statutory notice of deficiency, determined that petitioner was liable for deficiencies and additions to income tax as follows:
Addition to Tax Year Income Tax Section 6653(b)1 1978 ......... $23,237.53 $11,618.77 1979 ......... 50,832.81 ...
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