Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $39,599.29 in petitioner's Federal income tax for 1983 and additions to tax of $1,980 under section 6653(a)(1) and $9,900 under section 6661. Respondent also determined that an amount equal to 50 percent of the interest on the full amount of the deficiency was due under section 6653(a)(2). Unless otherwise indicated, all section references are to the Internal Revenue...
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