MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined deficiencies, additions to tax, and penalties for 1988, 1989, and 1990 with respect to petitioner AJF Transportation Consultants, Inc.'s (AJF) Federal income taxes as follows:
Additions to Tax Penalty Year Deficiency Sec. 6653(b) Sec. 6651(a)<...
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