Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the income tax of petitioners and additions to tax under section 6653(a) of the Internal Revenue Code of 1954 in the following amounts:
Addition Docket to Tax No. Year Deficiency § 6653(a) 5474-63 1959........... $253.99 $12.70 5475-63 1960...
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