Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $12,184 and $6,366 in petitioner's Federal income taxes for 1983 and 1984, respectively. Respondent also determined that petitioner was liable for additions to tax of $609.20 and $318.30 under section 6653(a)(1); 50 percent of the interest due on $12,184 and $6,366 under section 6653(a)(2); and $3,046.00 and $1,591.50 under section 6661, for 1983 and 1984, respectively...
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