Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax for the years 1958 and 1959 as follows:
Deficiency in Additions to tax under income tax Sec. 6651(a) Sec. 6653(a) 1958 .......... $11,837.67 $551.94 $719.30 1959 .......... 2,956.65 ....... 147.83
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