Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in the income taxes of petitioners and an addition to tax for the years and in the amounts as follows:
Addition to Tax Sec. 6651(a) Year Deficiency I. R. C. 1954 1959 ............ $2,099.83 $308.55 1960 ......
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