Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' income tax and additions to tax as follows:
Additions to Tax Income Sec. 6653(a), Year Tax I. R. C. 1954 1957 .......... $596.65 $29.83 1958 ........... 622.87 31.14 1959 ........... 493.13 24.66
The issues are (1) whether...
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