Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency of $21,373 in petitioner's 1987 income tax and additions to tax under section 6653(a)(1)(A) in the amount of $1,068.65, under section 6651(a) in the amount of $2,855.50, and under section 6653(a)(1)(B) in the amount of 50 percent of the interest payable on the underpayment due to negligence. All section references are to the Internal Revenue Code in effect for the year...
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