Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and an addition to tax as follows:
Addition to tax Year Deficiency Sec. 6651(a)(1) 1979 .............. $18,435 -- 1980 .............. 7,970 $1,195.50
After concessions, the sole issue for decision is...
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