Memorandum Opinion
WHALEN, Judge:
Respondent determined a deficiency in petitioner's 1981 Federal income tax in the amount of $10,817, an addition to tax for negligence under section 6653(a)(1) in the amount of $541, and an addition to tax for negligence under section 6653(a)(2) in the amount of 50 percent of the interest due on petitioner's $10,817 underpayment of tax. (All section references contained herein are to the Internal Revenue Code, as amended...
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