WELLS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Taxable Year Additions to Tax Under Section1 Ended Deficiency 6653(a)(1) 6653(a)(2) 10/31/82 $637,376.44 $31,868.82 * 10/31/83 602,206.61 30,110.33 * * 50 percent of the interest payable on the portion of...
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