MEMORANDUM OPINION
COHEN, Judge:
In separate notices of deficiency for each year, respondent determined the following deficiencies and additions to tax:
Additions to Tax, I.R.C. Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1995............. $2,864 $716.00 $155.29 1996............. 2,592 ...
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