Memorandum Opinion
HALPERN, Judge:
By notice of deficiency dated March 19, 1990, respondent determined deficiencies and additions to tax against petitioner as follows:
Additions to tax Taxable Year Deficiency Sec. 6653(b) 1979 ............... $3,746.610 $1,873,305 1980 ............... 3,749,352 1,874,676 1981 .................
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