Memorandum Opinion
CHABOT, Judge:
This matter is before us on respondent's motion for leave to file amendment to answer.
Respondent determined deficiencies in Federal individual income tax against petitioner for 1985 in the amount of $35,141 and for 1986 in the amount of $46,623, and additions to tax under sections 6653(a)(1) and 6653(a)(1)(A)
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