GEORGE C. PRATT, Circuit Judge:
Petitioner David A. Sullivan appeals from a decision of the United States Tax Court, Joel Gerber, Judge, that charged him with an income tax deficiency of $26,547 for 1983, plus additions to tax under 26 U.S.C. §§ 6651 (failure to file tax return), 6653(a)(1) & (2) (negligent underpayment of tax), and 6661 (substantial underpayment of tax) (1982). The commissioner agrees that the tax court erred in imposing additions...
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