MEMORANDUM OPINION
HALPERN, Judge:
By notice of deficiency dated January 22, 1999 (the notice), respondent determined deficiencies in, additions to, and penalties with respect to, petitioner's 1994 and 1995 Federal income taxes as follows:
Additions to Tax/Penalty Under Year Deficiency Sec. 6651(a) Sec. 6654 Sec. 6662(a) 1994 .......
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