MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice of deficiency dated September 23, 1993, respondent determined additions to tax for petitioner's 1983 tax year as follows:
Additions to Tax -------------------------------------------------- Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661(a) $3,351.50 50 percent of the ...
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