Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in the income tax of the petitioners and additions to tax for negligence for the indicated years as follows:
Addition to tax Sec. 6653(a), Year Deficiency I. R. C. 1954 1957........ $638.43 $31.92 1958........ 870.24 43.51
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