Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for 1984 of $56,939. Respondent also determined that petitioner was liable for the following additions to tax for its 1986 taxable year:
Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661 $1,575 50 percent of the $7,874 interest due on $31,496
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