MEMORANDUM OPINION
HAMBLEN, Judge:
By two separate statutory notices of deficiency each dated May 18, 1994, respondent determined deficiencies in the amounts of $19,124 and $18,956 in petitioner's 1990 and 1991 Federal income tax, respectively. Respondent further determined additions to tax for failures to file individual tax returns for the tax years 1990 and 1991 under section 6651(a) in the amounts of $174.75 and $195.25, respectively. Unless otherwise...
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