MEMORANDUM OPINION
DEAN, Special Trial Judge:
In a so-called affected items notice of deficiency, respondent determined petitioner is liable for additions to tax of $1,080 under section 6653(a)(1), 50 percent of the interest due on $21,604 under section 6653(a)(2), and $5,001 under section 6659 for the 1982 taxable year.
Petitioner concedes that he is liable for an addition to tax of $5,001 pursuant to section 6659 for...
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