Memorandum Opinion
NIMS, Chief Judge:
By statutory notice of deficiency dated August 23, 1988, respondent determined the following deficiencies in and additions to petitioner Sam Y. Kim's Federal income taxes:
Additions to Tax Year Deficiency Sec. 6653(b)(1) Sec. 6653(b)(2) Sec. 6661 1982 ..................... ...
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