MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge:
Respondent determined deficiencies in, additions to, and penalties on petitioner's Federal income tax for taxable years 1985 through 1990 in the following amounts:
Year Deficiency 6653(b)(1) 6653(b)(2) 6653(b)(1)(A) 6653(b)(1)(B) 6661 6663...
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