MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined income tax deficiencies in the amounts of $11,619 and $12,195 for petitioner's 1993 and 1994 taxable years, respectively. Respondent also determined that petitioner's 1993 and 1994 income tax returns were delinquent and that petitioner was liable for additions to tax in the respective amounts of $3,391 and $3,676 pursuant to section 6651(a)(1).
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