Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
Additions to tax—Sections Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6654 1982 $16,733 $4,183 $837 * -- 1983 12,260 1,716 613...
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