Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated April 14, 1989, respondent determined a deficiency in petitioner's Federal estate tax and additions to tax as follows:
Additions to Tax --------------------------------- Deficiency Sec. 6653(b)(1) Sec.6653(b)(2) $96,136.62 $48,068.31 ...
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