Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies and additions to tax against petitioner for the years and in the amounts as follows:
Addition to Tax Year Deficiencies Section1 6653(b) 1980 ......... $23,728.72 $11,864.36 1981 ......... 6,098.00 3,049...
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