MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6651(f) 1990 ................ $5,850 $3,304 1991 ................ 6,197 4,300 1992 ................ 6,640 3,551
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