MEMORANDUM OPINION
FOLEY, Judge:
By notice dated April 21, 1998, respondent determined the following deficiencies in, and additions to, Carol J. Jarboe's Federal income taxes:
Addition to Tax --------------------------- Year Deficiency Sec. 6651(a)(1) Sec. 6654 1991 ....... $ 7,788 $1,290 $280 1992 ....... ...
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