MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent issued a notice of deficiency to petitioner in which he determined the following Federal income tax deficiencies and additions to tax:
Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654 1995 $2,747 $ 533.75 N/A $112.10 1996 5,082 ...
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