MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $5,219 for 2000 and $9,164 for 2002, and additions to tax for failure to file under section 6651(a)(1) of $814 for 2000 and $1,746.23 for 2002, for failure to pay tax under section 6651(a)(2) of $465.66 for 2002, and for
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