MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies and additions to tax for 1987, 1988, and 1989 with respect to petitioner's Federal income taxes as follows:
Addition to Tax Year Deficiency Sec. 6651(a)(1) 1987 ................ $17,835 $4,459 1988 ................ 21,529 5,382 1989 ..........
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