MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency in, and additions to, petitioner's Federal income tax for 1988 as follows:
...Additions to tax Deficiency Sec. 6651(a) Sec. 6653(a)(1) Sec. 6661 $31,101 ................... $7,697 $1,766 $7,775
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