CATALFO v. COMMISSIONER

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined additions to tax as follows:

                 Additions to Tax
       ----------------------------------
Year   Sec. 6653(b)(1)    Sec. 6653(b)(2)

1984      $45,056        50 percent of the
                         interest due on
                         $90,112

1985       23,782        50 percent of the
                        ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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