MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge.
The petition in this case was filed in response to a "NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of determination).
The issues remaining for decision are:
(1) Did respondent correctly determine in the notice of determination that petitioner is liable for the additions to tax under section 6651(a)(1)
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