Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $3,548 and $22,207 in petitioner's Federal income taxes for 1985 and 1986, respectively. Respondent also determined additions to tax under sections 6651(a)(1), 6653(a), and 6654. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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