Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined the following deficiencies in and additions to the Federal income tax for taxable years 1984 and 1985 of Staff Outdoor Advertising, Inc., petitioner's wholly owned corporation:
Additions to tax Tax Year Deficiency Sec. 6651(a) Employment Tax ..... 1985 $ 5,583...
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